The Fate of Vitamins

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The Fate of VitaminsA low-profile organization created by the United Nations is about toban global trade of many essential nutrients—and there may be nothingyou can do to stop itBy Peter Byrne

Printer Friendly VersionIf you use vitamin and mineral supplements for health, you might wantto fly over to Rome, Italy and crash the July 4-9 meeting of the CodexAlimentarius Commission, a little-known international body that wields

immense power over the global food market. Should the Codex Commissionapprove the Draft Guidelines for Vitamin and Mineral Supplements onits agenda, 300 of the 420 basic vitamin and mineral products commonly

used by European consumers will be banned from manufacture and tradeinside the European Community.The ban will seriously impact the export business of U.S.-basedsupplement companies and could eventually result in similar product

restrictions being implemented here. The Codex story has receivedalmost no attention in the corporate press and media; although badlygarbled versions of the tale zing about in cyberspace, confusing manyreaders with conspiracy-laden mixtures of fact and fantasy. Which is

not to blame the authors of these emails, since the Codex Alimentarius(Latin for " food code " ) Commission is so pathologically bureaucraticthat its real intentions, and the probable consequences of its

actions, are difficult to discern when wading through thousands ofpages of jargon in its public reports. For example, it is not truethat over-the-counter vitamins and minerals will be banned in theUnited States after August 2005.

There are so many self-interested players in the " L'affair Codex, " that it is nearly impossible to get a straight answer about what itall means from any single participant. It is possible to piece

together the basic story from public records, and by listening to whatthe various interest groups have to say (with several tons of heavilyiodized salt). The bottom line of the story is that the emerging Codex

regulations on vitamins and mineral supplements have almost nothing todo with promoting human health, and everything to do with facilitatingthe profits of multinational food and chemical corporations.The Five Major Codex Players

From the point of view of the American health consumer, there are fivemajor players: the Codex Commission, the European Parliament and theCouncil of the European Union, the United Nations, the World Trade

Organization, and the U.S. Food and Drug Administration/U.S.Department of Agriculture. All of these institutions are involved informulating rules and regulations to govern the production anddistribution of food supplements. It is easy to conflate their

separate, but related, institutional efforts. The fate of foodsupplements is not dependent upon any one of these institutions, butupon how they interact as a whole. The five organizations are workingsyncretically to transform the supplements market, not in favor of the

consumer, but in favor of certain multinational corporations thatstand to benefit from the resulting restriction of trade under theguise of promoting " free trade. " The History of Codex and Their Guidelines

Codex was created in 1962 by the Food and Agriculture Organization ofthe United Nations (FAO) and the U.N. World Health Organization (WHO)to " harmonize " world food trade. The several hundred regular

" participants " at Codex meetings are drawn from the ranks ofgovernment regulatory agencies; food, chemical, and pharmaceuticalcorporations; industry trade groups; and non-profit " watchdogs " with

various political agendas. To date, Codex has established 250 sets ofrules regarding the manufacture and distribution of a variety offoods, from sardines to peanuts to pineapples, and including foodadditives and infant formula. (It is illuminating to learn that Codex

has approved the use of cyclamates and saccharine—artificialsweeteners long banned in the U.S. as health risks—as well asMonsanto's aspartame.) After more than a decade of wrangling overpolitical aims and technical details—far removed from the public

eye—the commission will likely approve the Draft Guidelines forVitamin and Mineral Supplements in July.The Codex guidelines begin: " Most people who have access to a balanceddiet can usually obtain all the nutrients they require from their

normal diet. " Vitamin and mineral food supplements are defined asconcentrated forms of nutrients whose purpose is to supplement thenormal diet when the vitamin and mineral intake from food is

insufficient. From the point of view of universal healthcare, decidingexactly which nutrients, and how much of each, constitute a " normal " or a " balanced " diet is a large variable when attempting to prescribe

a single standard across hundreds of dietary cultures.But Codex is not about health. The guidelines define the minimum levelof supplement use as 15 percent of the recommended daily allowance(RDA) suggested by the manufacturer. Maximum levels of use, or upper

safe levels, are not to be calculated by reference to RDAs, but, andthis is important, by " scientific risk assessment " based on generallyaccepted scientific data, taking into consideration, as appropriate,

the varying degrees of sensitivity of different consumer groups andthe daily intake of vitamins and minerals from other dietary sources.The key phrase here is " scientific risk assessment. " This

investigatory technique is, according to many experts, more properlyreserved for testing safe usage levels for chemicals and substancesknown to be inherently toxic or poisonous, not for evaluatingnutrients that are known to be generally safe as ordinarily ingested.

This emphasis in the guidelines, according to expert critics, closesthe door on the possibility of setting upper safe limits based uponthe benefits of using a particular nutrient. And by setting upperlimits based upon the sensitivity of the most sensitive group—say,

pregnant women who probably should not use a lot of Vitamin A—thelegitimate needs of the rest of the population for healthy doses ofVitamin A are ignored; indeed, the masses may be forbidden to use moreVitamin A than pregnant women, except, perhaps, by a doctor's

prescription. The " safe " upper limit paradigm is further drivendownwards by the admonition that it be reduced in accord with theamount of, say, Vitamin A obtained from a normal diet. Under Codex,

labels will advise the consumer not to exceed the maximum dailyamount; and that the product " should be stored out of the reach ofyoung children, " (replacing a sentence in an earlier draft thatrequired containers to be child-proof).

The Codex Commission, which is composed of voting representatives ofmost of the world's nations, has not yet set the exact maximum dosesfor vitamins and mineral supplements, but it is looking to theEuropean Union Parliament, and other arms of the FAO/WHO for

" scientific risk assessment " guidance in that regard. And that isbasically all that the Codex guidelines say at this time.Corporate ParticipantsIt is instructive at this point to take a look at the American

participants at the Codex Commission, i.e. public and private sectoragencies, corporations, and organizations that actively participate inthe commission's deliberations and wield considerable influence upon

issues in which they are acknowledged to be " expert. " Staff from theDept. of Agriculture and the Food and Drug Administration representthe official position of the United States at Codex meetings. They are

deeply involved in setting global standards, as are the staffs of foodand drug regulatory agencies in most industrialized countries. (Codexfunds " scholarships " for representatives from third world countries,

many of which lack any regulatory bodies, but are still subject to WTOagreements and are affected by Codex regulations.)From the corporate sector, official Codex participants include AmwayCorp., Wyeth Pharmaceutical Co., DSM Nutritional Products, Mead

Johnson Nutritionals, Bristol Myers Squibb Co., Nestle USA, HerbalifeInternational, and a trade group called the Council for ResponsibleNutrition (CRN). The latter's Web site features a " Myth vs. Facts " on

Codex, which, to be blunt, is a self-serving spin that underplays thenegative ramifications of the guidelines on mom & pop supplementbusinesses. CRN's membership includes Archer Daniels Midland Co.,

Cargill Health & Food Technologies, Bayer Corp., Wyeth ConsumerHealth, Weider Nutrition International Inc., Shaklee Corp.,Nutraceutical Corp., Herbalife International of America, Kemin Foods,General Nutrition Centers, Inc., Cadbury Adams USA LLC, DSM

Nutritional Products, Eastman Chemical Company, Mingtai Chemical LLC,and Monsanto Life Sciences Company. (A number of these corporationshave several voices at the meetings, since representatives ofcorporate subsidiaries sit alongside participants from their parent

companies. And corporate-funded lobby groups have separate voices.)CRN had this to say about the Draft Guidelines—which it helped towrite and of which it approves: " We in the industry have longmaintained that maximum levels set by Codex or governments for

contents of vitamins and minerals in supplements should be basedsolely and completely on safety, not on nutritional policy in generalor the RDA in particular. " It is instructive that the chemicalformulations for naturally-occurring vitamins and minerals are not

patentable, unlike pharmaceutical formulas. And the supplement marketis huge—$16 billion a year in the U.S. alone. It easy to presume thatpharmaceutical, chemical and agricultural concerns are working to grab

market share through the back door: Codex.Public Interest GroupsOn the other side of the corporate interest equation, in theory, isthe Washington D.C.-based Center for Science in the Public Interest,which along with sister non-profits from Japan and the United Kingdom

has official status in the Codex proceedings. CSPI is funded by socialengineering projects such as the Rockefeller Family Fund, John MerckFund, and the Robert Wood Johnson Foundation. A spin-off from Ralph

Nader's public interest organization, CSPI claims that Vitamin A,Vitamin D, and Vitamin B6 cause a host of horrible diseases. Thenon-profit, which is a quote mill for The New York Times reporters,

pooh-poohs the common understanding that a variety of foods andsupplements are healthy, such as soy, Vitamin C, antioxidants, anddietary fiber. To back-up its ultra-precaution, CSPI refers tomedia-ballyhooed studies of antioxidants and Vitamins A & E which

purport to show that these substances are bad for health. (Experts atHarvard Medical School and Tufts University say that these studies aredeeply flawed, largely because they were focused upon particularat-risk sub groups, and did not take the needs of general populations

into account.)CSPI's stance supporting restrictive standards for vitamin andminerals undercuts the usefulness of an otherwise fineenvironmentalist tool, the Precautionary Principle, by taking theposition that since a vitamin could cause harm to relatively small

groups of people if improperly used, it is permissible to ban ituniversally, regardless of its obvious and well-documented benefitsfor millions of people.Further complicating the mix of opinion massaging the medium is the

Hoover Institution, which has taken the position that Codexregulations hurt " free trade, " (a loosely defined, if politicallyuseful concept that is most often employed to justify the expansionistagendas of monopoly corporations). And the Center for Consumer

Freedom, a restaurant trade association set up to counter " food policelies " about the dangers of tobacco, olestra, trans fats, and obesity,frames Codex as the " global food cop. " Neither of these two

organizations participate in Codex.Institute of MedicineAnd then there is the Institute of Medicine (IOM), a quasigovernmental body based in Washington D.C. that performs scientificstudies on spec from government and private companies. It is under

U.S. government contract to develop standards for vitamins andminerals that reflect the standards being considered by Codex. Fromthe point of view of the scientific establishment, IOM is nolightweight; it is very influential at the FDA, and inside the

Codex/WTO complex.A series of IMO studies over the past half-decade assert that high-fatdiets lead to obesity and heart disease; that omega-3 fatty acids andlinoleic acid are good for health; and that there is no safe level of

consumption of trans fatty acids. (Codex regulations, on the otherhand, allow for trans fats in food, and consider meat to be a sourceof dietary fiber!) A 2000 IOM report found that Vitamins C and E andthe mineral selenium are health-positive, but that ceilings should be

set on their usage. IOM believes that antioxidants can be beneficial.It suggests daily intakes of 75 milligrams of Vitamin C (upper level2,000 milligrams); 22 IU of natural Vitamin E from food (upper level

1,500 IU of a synthetic variety); 55 micrograms of selenium, (upperlevel 400 micrograms). Beta Carotene supplementation, IOM says, shouldonly be used to prevent Vitamin A deficiency. Pregnant women shouldtake B vitamins, such as folate and choline to prevent neural tube

defects. IOM posits that most Americans get sufficient Vitamin B12 intheir food, except for people over 50 who should use supplements. IOMsays there is promising evidence that B vitamins play a role inreducing cardiovascular disease, cancer, and psychiatric disorders.

The Institute recommends upper levels of B6 at 100 milligrams per day;folic acid at 1,000 micrograms; and being wary of the rest of the Bvitamins.On the one hand, IOM has a higher regard for the health benefits of

supplements than does Codex officialdom, which is focused upon risk.On the other hand, IOM is tending in the opposite direction of manyknowledgeable health practitioners who typically recommend largerdoses. For example, the medical doctors and nutritionists staffing

Santa Rosa, California-based Farmacopia suggest, based on numerousstudies and years of practice, a daily Vitamin C intake of 500-1,000milligrams; Vitamin E intake of 400-800 IU; Vitamin A intake of

2,500-5,000 IU; Beta Carotene at 15 milligrams; and regular doses ofthe B vitamins, depending on need. Farmacopia's well-researchedprotocols spell out possible dangers from overdosing, such as nausea,diarrhea, and fingernail loss. However, they do not throw out entire

nutrient groups, or suggest upper limit doses for whole populationsbased upon possible dangers to the most at-risk groups.In reality, IOM's protocols are closer to Farmacopia's than to themore restrictive protocols supported by the ultra-precautionary forces

at the Codex Commission. And this is, in part, because the IOM studieswere funded by many of the same multinational corporations that aremonitoring the Codex deliberations to make sure that government andnon-profit bureaucrats do not go too far and end up liquidating the

marketability of their supplement products. The IOM studies referredto above were funded not just by the U.S. Dept. Health and HumanServices, but also by a variety of companies with varying degrees ofinterest in influencing Codex to set dose limits favorable to their

respective business plans. These include Daiichi Fine Chemicals Inc.,Kemin Foods Inc., M & M/Mars, Mead Johnson Nutrition Group, NabiscoFoods Group, Roche Vitamins Inc., U.S. Borax, and Weider NutritionGroup. The FDA, as we shall see, is now moving in the opposite

direction of the less-restrictive IOM recommendations. It funded a newIOM study, the results of which reflect that sea-change in supplementpolicy.Codex is nothing if not complicated. Its deliberations are fraught

with competition and collusion by profit-driven companies and thenon-profits that they fund to promote particular ideologies to justifyparticular business aims. Everybody at Codex is focused on grabbing

the brass ring: as much market control as they can pinch off forthemselves and their allies by tailoring the standards to fit theirmarketing needs. At stake in all the studies, discussions, politicalgames, legal maneuvers, and media manipulation is nothing less than

the determination of which vitamins and minerals end up on the " positive list, " i.e. an exclusive list of approved dietary substancesthat spells life and death for any number of global product lines.

The Positive ListOn April 5, 2005, the Alliance for Natural Health, an association ofhealth food manufacturers and distributors in the United Kingdomannounced a victory before the European Court of Justice in Luxembourg

in the form of an opinion by Advocate General Geelhoed. The opinionwill probably be adopted by the full court in June. The Alliance'svictory, however, is likely to prove minor and temporary.Here is the gist of the case. As of August 2005, dietary supplements

in the European Union will be regulated by the Food SupplementDirective approved by the European Parliament and the Council of theEuropean Union in June 2002. The directive calls for regulatingvitamins and minerals by establishing a " positive list, " which, in its

current incarnation, includes 13 vitamin forms and 15 mineral forms.Nutrients not on the list will be banned from being sold in the EU.The approved substances are broken down by chemical composition,favoring synthetic compounds of natural forms, according to the

Alliance for Natural Health. Substances not on the list includeseveral forms of Vitamin C, natural forms of folic acid, certainantioxidants, and a range of minerals including boron, vanadium,silicon, mixed tocopherols, tocotrienols, sulphur, chelated/plant

derived forms and natural forms of Vitamin E and selenium. Based onthe positive list, the EU directive will effectively ban 300 of the420 forms of vitamins and minerals present in 5,000 products currently

on the UK market.In response to the Alliance's lawsuit, the judge recommendedinvalidating the EU directive, but he upheld the concept of using apositive list to shape international markets, and he urged EU

officials to correct what amounts to technical glitches in the wordingof the directive, so that the positive list can be effectuated thissummer.Will the Existence of the Positive List Affect the American Market?

Undoubtedly, and here is how. First, in and of itself, the positivelist will prohibit the importation of excluded substances and productsinto European Community markets. Second, the list is sure to beincorporated into the Codex guidelines for vitamins and minerals. That

is because Codex is mandated to look to " accepted internationalstandards " to determine which substances are allowed and not allowedand at what doses. It is widely accepted by informed observers that

Codex will adopt the EU directive's positive list as its own standard,since there is no other internationally accepted standard.In order for a nutrient substance to be added to the positive list, acomprehensive risk-assessment study must be performed, with favorable

results submitted to the Office of the EU Communities by July 12,2005. Even then, it can only remain on the positive list until 2009.These expensive scientific studies can only be undertaken bygovernments or corporations with deep pockets. In sum, the EU

directive will likely destroy any European health supplement businesswhich produces or sells commonly accepted vitamin and mineral products.As for upper limit doses, the Codex Commission is looking to adopt the

specifications of a study conducted by the FAO/WHO and variousparties, including the Alliance for Natural Health. The study will setupper limit supplement dosage levels in the near future; and thosestandards, which will be based upon risk-assessment values, not health

benefits, will be incorporated into the Codex Alimentarius regulations.What does this mean for American consumers? Last year, the IOM, undercontract with the FDA, issued a report called the Proposed Framework

for Evaluation of Dietary Supplements. The report shifts IOM'sprevious focus upon health benefits to focus on scientific riskassessment. As in the Codex Guidelines, and the EU directive, IOM'sreport calls for safety issues to be considered as if there are no

health benefits attached to the use of a vitamin or mineral.Furthermore, it recommends a method of setting maximum doses that mayend up separating out ordinary usage (at relatively low levels) fromprescriptive use (

i.e., only medical professionals will be authorizedto prescribe supplements above certain dosages in the course ofmedical interventions). And, as does Codex, the IOM report recommendsputting the burden of supplying safety data upon industry—a strategy

that has been proven not to work—see Merck's murderous mendacity aboutVioxx.The Argument for CodexThe FDA and several large US manufacturers, like DSM NutritionalProducts, and Herbalife International, argue that the EU positive list

directive and its doppelganger, the Codex guidelines, will not affectthe ability of American consumers to use high doses of any supplementthey wish to consume because the Codex guidelines and the EU directive

are more restrictive than the Dietary Supplement Health and EducationAct of 1994 (DSHEA); and the FDA is not adopting the positive list andits presumed low dosage standards, per se. In other words, Americanconsumers will still be able to import European supplements because

those products will be lower dosed than the current unlimited dosagelevels allowed in the U.S. However, American supplement manufacturersand distributors will be locked out of the European regional markets,

and the local markets of any country that adopts the Codex standardsin order to benefit from trade with Europe.Let us not forget that the same American corporations that sit on theCodex Commission as participants also wield tremendous power within

the FDA and Congress. Above all, these corporations want access to—andexclusive control of—existing and emerging markets. For DSM Nutrition,for example, the Codex restrictions bring multiple benefits. They kill

off small competitors, for all the reasons listed above, and alsofacilitate the development of two-tiered supplement products, a lowdose vitamin for over the counter purchase, and a high dose, moreexpensive item for prescriptive use. Supplement users stuck in a

Codex-controlled market will no longer be able to legally supplythemselves with nutrients and doses of their own choosing; rather,they will be captive to the monopolies.In March, the FDA observed that, " The absence of science-based Codex

guidelines [in America] could adversely affect the ability of U.S.manufacturers to compete in the marketplace. " This is true because thetrade ministries of countries that adopt the Codex standards will

repel non-Codexed products. But what the FDA did not say is thatEuropean supplement companies will no longer be able to compete in theU.S. market, because their products will be inferior to Americanproducts by fiat. And that phenomenon, under the WTO treaties that

prohibit a government from " artificially " restricting " free trade, " could hypothetically be construed to mean that our relatively looseFDA regulations " unfairly " restrict the ability of European producers

to export to the American market, potentially forcing, under the WTOtreaties, Congress to adopt Codex standards to facilitate " freetrade. " Whether or not it falls out like that, it is clear the FDA is

moving under its own steam toward cloning the emerging Codexstandards, which it helped to develop as a leading participant incommission deliberations.A Brief SummaryTo sum up so far: the Codex Commission is mostly composed of corporate

officials from the agribusiness, pharmaceutical, and chemicalindustries, and government officials that " regulate " those industries(often after or before working for those same privately-owned

industries). Codex is poised to adopt a " scientific risk assessmentstandard " for evaluating vitamins and mineral food supplements. Due tothe use of that method of analysis, as opposed to a " risk-benefit "

analysis method, the Codex standard will likely incorporate thepositive list of the EU directive. It may adopt upper dosage limitsthat are lower than RDA doses currently available in ordinarysupplements. (Higher doses may later be regulated as prescription-only

drugs.) In Europe, hundreds of relatively small supplementmanufacturers and distributors fear that the new Codex restrictionswill annihilate their businesses—leaving the field open tocorporations that can afford the expense of having proprietary,

synthetic supplements added to the positive list through 2009, longenough, perhaps, to ensure domination of a drastically reshaped market.The Codex restrictions ensure that the quantity and quality ofsupplements that can be imported by the European market from America

will diminish. But in the U.S. there is a government-corporatepropaganda campaign dedicated to assuring American consumers and smallsupplement producers that they are in no danger of ending up liketheir European counterparts. Large companies such as Herbalife

International say that anyone who suggests that Americans will loseaccess to supplements is plying " misinformation. " The company goes sofar as to tell its international network of distributors that

corporate HQ represents them at Codex meetings, and they will be toldwhen, if ever, to open their mouths. In July 2003, the Consumers Unionhailed the scientific risk assessment standards of Codex. AmericanHerbal Products is slightly more perspicacious. This trade association

recognizes that the WTO can, at least in theory, push the Codexstandards upon Americans.Why Is There Confusion About Codex?One of the reasons that U.S. trade associations and consumers are

confused about Codex—and why pro-Codex lobbyists, such as the FDA andthe CRN, can dismiss the legitimate concerns of consumers asconspiracy theories—is because, due to the complexity of thebureaucracy at work, people have conflated the Codex Guidelines (which

has no positive list, nor an upper dose limit, yet) and the EUdirective (which does have a positive list, but no upper dose limit,yet). Reading the FDA's or CRN member's barrage of disclaimers aboutthe negative impact of Codex upon the U.S., one is struck by theshared mantra that compliance with Codex is " voluntary, " when, intruth, non-compliance may result in trade sanctions or expulsion fromthe WTO. Another popular phrase that pops up in the campaign,

" science-based risk assessment, " sounds nice until you realize it is atechnique more aptly applied to arsenic or cyclamates, than to VitaminE, which has known benefits, (as well as some risk if used improperly).

The fact that too much of a good thing can cause harm has been blownout of proportion by Codex proponents. For instance, a study of theeffects of Vitamin E upon smokers and cancer victims has been widely

publicized as " proving " that the vitamin has no positive effect onhealth (and may result in death); whereas dozens of unpublicized,scientifically-superior studies show that Vitamin E has many benefits

(and that the negative study was deeply flawed). Or take the case ofthe amino acid, L-tryptophane, demonized a few years back after agenetically-engineered batch manufactured in Japan was fatallycontaminated. Instead of questioning the efficacy of genetic

engineering as a manufacturing strategy, or the wisdom of replacingnatural substances with synthetic, proprietary goop, thepharmaceutical-regulatory establishment attacked L-tryptophane in all

of its forms, many of which are beneficial. Underlying all the publicrelations blather, and reams of subjectivized, financially compromisedstudies, is the fact that world trade in food supplements is beingrestricted and transformed for the worse under the guise of

eliminating trade restrictions and promoting health.Enter the WTOContrary to rumor, Vitamin C will not be banned in the U.S. in August.But some forms of it will be banned in the EU; and a similar ban could

eventually appear in the U.S., although that event is not inevitable.On the other hand, it will be much more difficult for ordinaryconsumers to stop this eventuality than it was for them to affectDSHEA, which was transformed by consumer pressure from a restrictive

measure into its opposite. In fact, the very existence of DSHEA isused by Codex proponents as " proof " that the U.S. is protected againstCodex, because DSHEA is " less restrictive " than Codex and the EU

directive. That is hollow reassurance.DSHEA is a malleable act of Congress, subject to constituent pressure.The implementing force of Codex—the WTO—is based upon an internationaltreaty to which the United States is a party. And the WTO does not

care a fig for people's health concerns. It is designed to manipulatethe formation and deformation of trade barriers in favor of thestrongest monopolists.Here is how it works. The WTO derives its power to regulate

international trade through treaties. In the age of the political,cultural, and economic dominance of multinational corporations, itacts as a kind of clearing house, or court of last resort, to settletrade disputes short of war. In theory, the WTO is concerned that no

country favor its own exports by placing " unfair " restrictions uponcompeting imports.Run by and for the interests of large industrial and financialenterprises, the WTO views " harmonization " of food standards as

promoting " free trade. " Unfortunately, free trade as conceptualizedand actualized by the dominant WTO members (United States, EuropeanUnion, Japan) is not about leveling the playing field so that small

producers or underdeveloped countries can compete with the big guys.It is about ensuring that the most powerful corporations can continueto grow, eating up the small fish and expanding into new markets inboth industrialized and industrializing economies. It is about

maximizing the extraction of profit for stock-holders, as opposed tomaximizing the health or economic well-being of a population.To that end, WTO members have agreed to abide by the Agreement onSanitary and Phytosanitary Measures (SPS), and the Technical Barriers

to Trade Agreement (TBT), which mandate that no country will imposeunfair barriers to trade, and that they will work to harmonizeregulations that affect trade by abiding by international standards,or face trade sanctions. In theory, this could mean that the United

States, by allowing the internal sale of substances and supplementdoses that are disallowed in Europe is, in effect, imposing a barrierto the " free trade " of EU supplements, since consumers are less likely

to buy products that are diluted by Codex restrictions. And the FDA,which is clearly controlled by the pharmaceutical and agribusinesssector, is in the process of harmonizing the internal market, partlythrough the scientific auspices of the IOM, in a way that parallels

the EU Community and Codex processes. From the perspective of the WTO,it is not harmonious to have one relatively unrestricted supplementmarket, governed by DSHEA, surrounded by a more restricted worldmarket bound under Codex. Since it is, when all is said and done, in

the interests of the WTO movers and shakers to carve up the foodsupplement market amongst themselves, while excluding small producers,it is likely that the movement to mirror the Codex restrictions in

America will continue. And should that fail, the SPS and TBT treatiesensure that legal actions can be mounted by European governments atthe WTO level to compel the U.S. to toe the Codex line, or pay the

price of non-compliance.(It is important to note that food and food supplements are only onearea of commerce that the WTO and the United Nations are attempting toharmonize. Ultimately, world trade will increasingly fall under the

spell of monopoly as commodities become uniformly regulated inconformance with the Neoliberal economic doctrine [the so-called " Washington Consensus " ] that currently prevails in the White House, at

the United Nations Security Council, and inside the WTO.)The Irony of the SituationThe ultimate irony, some might say horror, of the situation ishighlighted by looking at a joint report by the FAO/WHO issued in

2003, Diet, Nutrition and the Prevention of Chronic Disease. Thisimpeccably researched, enormously valuable study—performed by otherarms of the same organizations that administer Codex—finds that thehealth of Third World populations is being destroyed by importing the

First World diet, which is heavy in saturated fats, trans fats,unrefined carbohydrates and sugar, meat, dairy, while lacking invegetables, fruits, and dietary fiber. This unhealthy diet, says theFAO/WHO, is spreading around the globe " like an infectious disease. "

Without mentioning Codex, the report implicitly damns the commission'smethods and its guidelines for vitamins and minerals. For example, thereport notes that " [Food] guidelines should try to ensure that the

overall benefit of recommendations to the majority of the populationsubstantially outweigh any potential adverse effects on selectedsubgroups. " In other words, upper dosage limits for supplements should

be set to benefit the population as a whole, not calculated, say, onthe potential for excessive intake of Vitamin A to harm a fetus. " Population nutrient goals recommended by FAO/WHO [should be] tailored

to local or national diets and populations [to] reverse or reduceimpact of unfavorable dietary changes occurred over the past century[and in] developing countries recently. " Of course, the WTO is notabout to base trade rules on health issues. Rather, with the

assistance of the International Monetary Fund and the World Bank,Third World markets are being inundated with fast and processedfoodstuffs, even as their trade balances are undermined by theimportation of meat, dairy, sugar and refined grain. In short, the

natural economies serving billions of people are being turned to dustby transnational agribusiness, which, in taking over local foodindustries and promoting bad diet, cause the need for vitamin andmineral supplements to increase at the very moment that the

population's ability to access natural pharmacopeias is beingcurtailed by Codex's profit-maximization scheme. The rise ofdiet-related chronic disease is good business for biotech corporationssuch as Cargill that sell food and food ingredients while positioning

themselves to market cancer cures, cardiovascular drugs, and dietaryfood supplements.Regarding upper dosage limits for supplements, the FAO/WHO reportobserves, " Seldom is there a single 'best value' [instead] there is

often a range of population averages consistent with maintenance ofhealth … the recommended dietary/nutrition practice should modify theattributable risk of the undesirable exposure in that population. " In

other words, national-level regulations can best serve the needs ofnational populations. And responsible labeling practices protectconsumers by informing them about the dangers of over-dosing.The FAO/WHO study advises eating fruits and vegetables, shying away

from red meat, saturated fat, and refined sugar, while exercisingregularly, and avoiding television. It promotes the use of vitaminsand minerals (including substances excluded from the EU directive's

positive list) for fighting cancer, cardiovascular disease, diabetes,and the other ills that come from eating nutrient-stripped,flavor-added " food. " Which brings us back to the opening sentence of

the Codex Guidelines: " Most people who have access to a balanced dietcan usually obtain all the nutrients they require from their normal diet. " ConclusionClearly, most people, even in America, do not have access to a

balanced diet and the nutrients they require. Supplements are one wayof alleviating the symptoms of a globalizing problem that can only besolved by an epochal transformation of the planet's political economy.

It is not just irresponsible for the Codex Commission to throttle theglobal market in food and food supplements when 2.8 billion people areforced to live on less than two dollars a day; it is malign.But even in the world's most over-consuming society, corporate

domination of the food and drug supply is wreaking havoc. As reportedin the Journal of the American Medical Association, and elsewhere,food-borne diseases contribute to approximately 76 million illnesses,323,000 hospitalizations, and 5,200 deaths in the United States alone

each year, while properly prescribed and administered prescription andover the counter drugs are estimated to cause annually 2.2 millionserious adverse events, and some 106,000 deaths in the UnitedStates—while " regulators " sit by idly. The normal use of vitamins and

minerals, on the other hand, is not a death sentence.© 2005 Peter Byrne. Peter Byrne is an award-winning investagativejournalist. He hangs out at

www.peterbyrne.info-- Diana Gonzalez Nothing wastes more energy than worrying - the longer a problem is carried, the heavier it gets. Don't take things too seriously - live a life of serenity, not a life of regrets.

-Unknown