EU Novel Food List
In a world that is evolving faster than any other time in history it is all too easy to streamline or automate processes in a way that potentially infringe our basic human rights that should be prioritised over the interests of multinational business or the associated industry regulators. In the words of Nelson Mandela “To deny people their human rights is to challenge their very humanity.”
There is little doubt that modern technologies have benefited recent generations in many ways. However, it has also made our digital footprint ever more accessible often exposing our personal information, buying patterns, personal habits or political views to the digital data industry, currently worth an estimated sixty four billion dollars revenue in 2021 and an estimated 100 billion dollars by 2027
As these large commercial organisations pursue the data evolution to stay one step ahead of their opposition, we believe these changes to our lifestyles should be evolved in a manner that protects and respects our human rights that so many have given their lives to protect.
For example, there are many concerns about the power of large international organisations that often pay little or no taxes that are part of what is now being called the great reset or the one world order, in effect giving greater powers over our lives to a small number of unelected wealthy individuals who seem to be unaffected by organisations like the somewhat defunct monopolies commission.
We are an organisation who are not only committed to keeping you updated on the possible key areas where we see a conflict of interest between your human rights and the interests of big business, but we are also committed to supporting legal regress where we feel this is appropriate.
We very much hope you will follow us as we start to develop these areas of action and do share our work with interested friends and family, after all we are here to support your interests, not our own.
One of the key areas we have identified as a potential conflict of interest between our basic human rights and the interests of big business is our ability to have the freedom to purchase whatever foods or food supplements, we select or require supporting us through some of the most challenging times for the UKs population, which one assumes is in our best interest and the interests of our struggling NHS.
In these most challenging of times it’s essential that we challenge the open censorship by large corporations like Google and Facebook, plus many other large social media sites or perhaps better simply stop using these organisations products and thus no longer reward these organisations with our patronage until this needless censorship is repealed and we are allowed the freedoms necessary to obtain an informed view, enabling us to give our chosen health pathway our informed consent, which is something that after all is not optional, but a legal requirement.
In particular, we are concerned that Brexit in its current format, allows the Food Standards Agency (FSA), “an independent Government Body” to adopt rules and regulations from Brussels that simply don’t fit into British law, as they forbid us to do things unless they have been approved by this organisation, rather than as is the norm within British law we are allowed to do anything unless we have been told we can’t, allowing the consumer greater freedom of choice.
If this current approach remains unchallenged, the FSA have the right to claim that any new products launched in the UK without substantial distribution within the UK before 1997 can be viewed as a “Novel Food” and thus reviewed in a process without a obvious appeals process and removed from sale without any recourse to industry stakeholders or the consumer.
We now, therefore, intend to challenge the FSA’s current approach and implementation of the EU Novel Food directive into UK Law and if necessary, we will call for a Judicial review and the right to create a regulatory process that respects the British principles that we can do whatever we like unless they have explained fully why its not in our best interests to do so.
We are therefore now communicating with the associated Government bodies to ascertain the following information:
Consideration
We note that European Union Regulation (EU) 2015/2283 is retained and that the EFSA guidance remains relevant in this regard after 01.01.2021. There is a level of confusion as to how the consideration process functions without the EFSA multi-member involvement. It would be most helpful to have clear direction on how the process is now conducted in relation to Article 4 (4). As you will be aware Article 4(4) required adherence to Article 30 (3). Article 30 was omitted by Statutory Instrument 2019 No. 702 Part 3 Regulation 35. The instrument Annex 2 provides only samples of template technical dossiers and no information on the consideration procedure.
Placement
It is apparent as the appropriate authority the procedural steps for determination of novel food status in accordance with Regulation (EU) 2015/2283 (as retained) will now be actioned in the England, Wales, and Northern Island by the FSA, and as regards Scotland, by Food Standards Scotland. It is unclear from the available guidance as to whether the FSA are applying the same food categories as were previously determined by the EFSA. It is also unclear as to how a decision would be made to add or subtract food categories.
Consideration Body Appointment
At the early stages of the novel foods authorisation process the Advisory Committee on Novel Foods and Processes (ACNFP) will carry out an assessment to decide if the product or process is safe to be placed on the market in England, Wales and Scotland. Based on this evidence, The FSA will consider possible risk management options and make a recommendation to ministers.
It is to be expected that a committee with such a high level of responsibility for public protection has a robust process for selection of its membership. Would you kindly provide direction as to where the selection and removal procedures for members of the ACNFP may be found?
Right of Appeal
The process for the authorisation under either a traditional food notification or a full application is described under the Regulated products application guidance on the FSA website. The guidance, nor any other area of the FSA website site appears to reference an appeal process. Does such a facility exist?
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