What this means in practice is that the levels will be set well below the USLs, which are likely to be absurdly low in the first place.
The SCF, a body composed of food technologists rather than nutritional doctors, has made a few noises about where it stands on a number of nutrients which are, in themselves, worrying. For instance, it has indicated that the USL on B6 should be 25 mg far lower than the US National Academy of Sciences' USL. Indeed, as their support for their safety level of B6, they relied on the Dalton study, a trial which was soundly criticised when the UK government considered and ultimately abandoned a law that would limit the sale of B6.
>From that 25 mg then would be subtracted a certain amount for the B6 in a normal diet, another amount to compensate for fortified foods and a final amount to provide a wider safety margin to demonstrate the SCF's intention to use "caution in risk management". What may finally emerge is a level of B6 as low as 5 mg. This would mean that British women taking B6 for premenstrual syndrome (PMS) usually 50-100 mg per day would have to swallow 10 to 20 vitamin pills a day just to maintain the levels they are used to.
These limits may also reflect the majority views of the member states. Although the UK, Holland and Sweden are likely to vote to keep high dose vitamins alive, in 1992, 11 of the EU governments sought a very low upper potency limit for their products.
In some cases, this amounted to 2-3 mg for vitamins B1, B3 or B6. This is 1/25th of the amount usually stipulated by nutritional doctors, such as those members of the British Society for Nutritional and Environmental Medicine who may recommend, as standard, 50 mg of some of the B vitamins as a minimum dosage.
The problem with these criteria is that they attempt to encapsulate the eating habits and climate of every individual European member state into one broad ruling. It puts into the same hopper countries that use lots of fortified foods with those who mainly use fresh ingredients. A country like Britain, which has a highly processed diet, is placed in the same category as one of the Mediterranean countries, which consumes a healthier diet. It means that cold northern countries such as the UK and Scandinavia will have the same levels of vitamin D in their supplements as sun rich countries like Spain and Italy.
Any vitamin which exceeds the doses set will be cleared off the shelves unless the company applies for, and receives, a pharmaceutical licence. Such a licence is so prohibitively expensive that it will be beyond the reach of all but the very largest vitamin firms.
The crux of the issue, according to Ralph Pike, director of the National Association of Health Stores in England, is the criteria the Commission will use to determine USLs. Most, if not all, the ministers will be unfamiliar with the breakthrough work in nutritional medicine, which uses high doses of vitamins to prevent and treat disease. It is more than likely that they will rely heavily on standard intake measures or a limited tool like the RDA, which is a standard of the minimum nutrients needed to prevent deficiency diseases such as scurvy (see box, p 2).
Furthermore, if the recent meeting of 6 December is anything to go by, a number of the member states would like to restrict things even further. For instance, Austria and Greece are pushing to have the directive's criteria eliminate USLs and use PRIs, a move that will limit vitamins to the very low levels of the RDA. France, Germany, Italy and Spain are also pushing hard to use population reference levels.