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Application A577 – Calcium in Chewing Gum containing no more than 0.2% Residual Sugars – Draft Assessment Report

7 February 2008

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.

NZFSA supports the addition of calcium to chewing gum with no more than 0.2% residual sugars (≤ 0.2% residual sugars) in principle because

• NZFSA recognises the public health benefit of additional calcium for certain sectors of the population; and

• FSANZ’s risk assessment shows there is no risk of over consumption of calcium from calcium fortified chewing gum (≤ 0.2% residual sugars).

However NZFSA does not support option two in regards to

• creating a stand-alone standard for chewing gum and thus separating the permissions to fortify chewing gum (≤ 0.2% residual sugars) from all other permissions to fortify in the Code under Standard 1.3.2; and

• the manufacturer determining serving size as opposed to a specified reference quantity to determine the minimum amount of calcium required to make a claim.

Specific comments are documented here in the order the issues they relate to appear in the Report.

1.2.1 Use of the term ‘chewing gum containing no more than 0.2% residual sugars’

NZFSA supports the use of this term to describe the product that is the subject of this application. We agree that the alternative, to use the term ‘sugar free’, would not be appropriate as in New Zealand the term ‘free’ means absolutely free under the Fair Trading Act.

1.3.1 Amendments to the original Application

• permit claims ‘per serve’ rather than a prescribed reference quantity, which are used in Standard 1.3.2 – Vitamins and Minerals.

NZFSA does not support the proposed change to permit claims ‘per serve’ rather than a prescribed reference quantity. The original application sought to allow the addition of calcium to chewing gum (≤ 0.2% residual sugar) at a level per reference quantity, to be based on a ‘normal serve’. NZFSA supports a reference quantity based on a normal serve being set. The draft assessment report (DAR) states (p 20) “of those who reported consuming chewing gum (≤ 0.2% residual sugars), either pellets or tabs, the majority reported consuming it less than once a day; when they do consume it, over 85% reported consuming either one or two pellets or one tab on any one occasion”. We suggest therefore that the reference quantity be set at two pellets (2.8g).

The report also states (p 21 ‘Scenario 1’) that, with current technology the amount of calcium that can be added to chewing gum (≤ 0.2% residual sugar) is 21.3mg releasable calcium per gram of chewing gum. With the average pellet weighing approximately 1.4g (NZFSA estimation), it is currently not technologically possible (according to the applicant) to add enough calcium to make a claim (ie 10% of the RDI or 80mg) to a typical serve of 1-2 pellets (21.3mg x 2.8g = 59.6g). There may be an incentive without a specified reference quantity for manufacturers to increase the serving size stated on a pack to three pellets to enable the required amount of calcium to be added to make a claim as to its presence. As the research presented in the DAR states that most chewing gum consumers eat one to two pellets per chewing occasion, to make a claim regarding the presence of calcium in the gum based on a serving size of three pellets would be misleading. NZFSA supports a reference quantity being set for chewing gum at a level of two pellets.

3.2 Ministerial Policy Guidelines

In the Policy Guidelines for Voluntary Fortification the specific order principles state “The fortification of a food, and the amounts of the fortificant in the food, should not mislead the consumer as to the nutritional quality of the fortified food.” This principle would not be met if the amount of gum required to be consumed to obtain the amount of calcium required to make a claim (ie 10% of the RDI or 80mg) is larger than the amount generally consumed by gum consumers per eating occasion. Prescribing a realistic reference quantity for chewing gum (≤ 0.2% residual sugars) would overcome this.

7.2.1.1 Chewing gum (≤ 0.2% residual sugars) consumption patterns

The survey conducted by Roy Morgan Research reported that of those who reported consuming chewing gum (≤ 0.2% residual sugars), the majority reported consuming it less than once per day, and when they do consume it over 85% reported consuming either one or two pellets or one tab on any one occasion. NZFSA supports a serve size of two pellets on which to base any claims.

7.2.1.2 Scenarios used in the dietary intake assessment

NZFSA notes that according to the applicant only under scenario two “Anticipated future technology” would enough calcium be able to be incorporated into what consumer research has shown to be a ‘normal serve’ to be able to make a claim. We note that the applicant feels this is not technologically possible at the present time. NZFSA questions how chewing gums sold as therapeutic goods (the examples Recaldent^TM and B-Fresh Gum are given in the application) are able to achieve higher levels of calcium per pellet of gum if this is not technologically possible at present. If this technology is available we support a requirement for a minimum 10% of the RDI for calcium to be present in two pellets of gum, as this is in line with the amount of gum consumers chew per chewing occasion.

10 Options

10.2 Option 2 – Prepare a Stand alone Standard for chewing gum in Part 2.10 of the Code that permits the addition of calcium to chewing gum (≤0.2% residual sugars) at a maximum claim level of 200mg releasable calcium per serve.

NZFSA does not support the development of a stand-alone standard for chewing gum.

The aim of the Standards setting process should be to achieve minimal necessary standards, while ensuring FSANZ objectives in developing food standards are met.

NZFSA believes all requirements in the proposed draft Standard for chewing gum can be covered by general permissions for voluntary fortification in the Code, with the exception of the requirement for a statement to the effect that the maximum claim per reference quantity and the maximum permitted quantity of calcium per reference quantity (Standard 1.3.2 Table to clause 3) are to be based on the average quantity of calcium released during 20 minutes of chewing. The requirement for this statement could be included in Standard 1.3.2 along with permissions to fortify chewing gum (≤ 0.2% residual sugars), by qualifying the values in columns 4 and 5 of the Table to clause 3.

Draft variation to the Australia New Zealand Food Standards Code

If FSANZ proceeds with the stand-alone standard for Chewing Gum as proposed, the purpose of Standard 1.3.2 Vitamins and Minerals will need alteration to include “the addition of calcium to chewing gum (≤ 0.2% residual sugars) Standard 2.10.3” in the list of foods to which Standard 1.3.2 does not apply.

Yours sincerely