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Application A532 – Ratio of Long Chain Polyunsaturated Fatty Acids in Infant Formula – Draft Assessment Report

4 July 2007

Dear Sir/Madam

Thank you for the opportunity to comment on this application. The New Zealand Food Safety Authority (NZFSA) has the following comments to make on the Draft Assessment Report.

• NZFSA supports the preferred approach (Option 2) that would require an amendment of Standard 2.9.1 to require an omega 6 to omega 3 long chain polyunsaturated fatty acid (LCPUFA) ratio that is not less than 1, should LCPUFAs be added to infant formula. (We did not support this option at Initial Assessment as no ratio was specified).

• The omega 6 to omega 3 ratio of approximately 2 in Standard 2.9.1 was based on the best scientific evidence at the time. NZFSA recognises however that new research has emerged and the ratio of 2 may no longer be appropriate. NZFSA is satisfied with the risk assessment and welcomes the independent review conducted (as requested in our Initial Assessment Report submission).

• NZFSA supports consistency with the Codex Alimentarius Draft Infant Formula Standard and the European Commission Infant Formula Directive, which both imply that the ratio of arachidonic acid to docosahexaenoic acid is not less than 1 when LCPUFAs are added.

• NZFSA is satisfied that the maximum percentage of total fatty acid levels for omega 6 and omega 3 fatty acids remain unaffected in support of Option 2, and supports the retention of this provision in Standard 2.9.1.

Yours sincerely