SAGMA sent a proposal in Brazil in relationship to the public consultation opened by ANVISA (National Agency of Sanitary Control). Said consultation referred to a proposed regulation aimed at setting the maximum content of chrome and copper in food and beverages.

In relation to chrome SAGMA suggested a new wording of the resolution. The purpose of the modification in the text was to help to a better understanding that the public consultation was not the gelatin as an ingredient but the water jellies and the powder used in the preparation of water jellies. SAGMA proposal was to settle a limit of 10 mg/kg.

SAGMA mentioned several sources to give support to its position:

  1. In the Unites States of America, chrome is an element considered as GRAS (Generally Recognized as Safe) when it is used in beverages.

  2. The European Union regulation (EC) 853/2004 has a maximum limit of 10 ppm for gelatin and collagen.

  3. The European Pharmacopeia also set a maximum of 10 ppm for the gelatin.

  4. The Code for Food Chemical Products in the United States of America includes a maximum limit of 10 ppm for the gelatin.

  5. The South American Common Market (MERCOSUR) regulation # 12/2011 doesn’t put any limit of chrome for food products.

A mission from the EU visited Brazil in last October. They interviewed Brazilian sanitary authorities, but also visited several gelatin plants, tanneries and slaughterhouses.

The purpose was to evaluate the controls over both, the gelatin production and the raw material used to produce gelatin for human consumption, destined to the EU. According to the Ministry of Agriculture, Cattle and Supply (MAPA as per their initials in Portuguese), all the Brazilian Gelatin Industries will continue to be approved to export to Europe.

All the gelatin factories visited were found in conformity with the relevant European requirements.

A preliminary report of the inspection was announced in approximately two months after the visit. However, up to now, it didn’t arrive to Brazil.

SAGMA together with all other regional associations of the gelatine industry – GME, GMIA and GMAP – requested the TAH Code commission the change and rewrite the chapter 2.3.13. The gelatine manufacturers, considering the results of recent scientific studies referring to the safety of the gelatine production process and the capacity to eliminate eventual BSE infection, proposed to remove all BSE restrictions for gelatine produced by bone raw material.

In mid February 2006 SAGMA sent a letter containing the proposed modifications to the General Director of the OIE, Dr. Bernard Valat and to the chairman of the Code Commission, Dr. Alejandro Thiermann as well as to the OIE delegates located in the SAGMA related countries in order to consider our letter on the Commission meeting in March.

SAGMA has recently taken notice of the results from this meeting and is analysing the recommended modifications of the Code commission foreseen to be voted during the 74th General Assembly of the OIE to be held in Paris between May 21 and 26, 2006. Depending on the outcome of our analyses SAGMA might ask for additional changes, modifications of the referred chapter.