I am voting "Negative" on the proposed standard revision as EFSA policies should not take precedence over U.S. FDA's regulatory guidance on caffeine contained in foods, beverages and liquid dietary supplements. The proposed standard revision would even go beyond the caffeine limits stipulated in FDA's final rule on stimulant drug products (21 CFR Part 340). Furthermore, even the EU references data indicating that a large part of the European population habitually exceeds 400 mg per day of daily consumption with no apparent adverse health effects. Finally, establishing more restrictive limits without the basis of a preponderance of scientific support, or agreement --- or compelling safety dangers associated with existing standards and guidance --- would only serve to add confusion, not clarity, to the U.S. national posture on caffeine and to decisions of international bodies which reference or accept voluntary NSF/ANSI standards.
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