Memorandum by the Food Standards Agency
Nanotechnologies may offer a range of potential
benefits to consumers and industry in the area of food and food
contact materials, from improving the solubility and bioavailability
of ingredients to extending the shelf-life of food. Nanotechnology
applications for the food sector have raised a number of safety,
environmental, ethical, policy and regulatory issues. The main
concerns stem from the lack of knowledge about the potential effects
and impacts of nanomaterials on human health and the environment.
Nanotechnology has been defined by The British
Standards Institute (BSI)
as "the design, characterisation, production and application
of structures, devices and systems by controlling shape and size
at the nanoscale", where the nanoscale is defined as the
size range from approximately 1 nm to 100 nm. For comparison,
a single human hair is about 80,000 nm wide. Similarly, a
nanomaterial can be defined as any material with at least one
dimension in the nanoscale.
According to this definition, the term "nanotechnology"
can encompass a wide range of products, processes and applications
whose sole unifying factor is that they are linked in some way
to the nanoscale. For example, the term would include:
tiny water-filled fat droplets, which
are being investigated as an ingredient for use in reduced fat
products such as mayonnaise
incorporating fat-soluble vitamins into
nano-sized packages (micelles) that will dissolve in water
the understanding and modification of
the fine structure of food products such as ice creamfood
technologists are looking for ways to replicate the physical properties
of such foods in products with a reduced fat content
investigation of the structure-function
relationships of enzymes, which play a central role in many types
of traditional food processing
nano-particles of titanium dioxide, which
are used in transparent sunscreen products (no known food applications)
nanoparticles of silver, which are used
for their antibacterial properties in a range of consumer goods
and which may find applications in food containers
carbon nanotubesthin cylinders
made of carbon atomswhich are being used as a structural
component of consumer products such as tennis racquets and golf
clubs (no known food applications).
It may therefore be misleading to discuss "nanotechnology"
in relation to food as if it is a single discipline, and the applications
of nanoscience are more accurately described in the plural as
The principal area of interest and concern in
relation to food appears to be engineered nanomaterials, which
are specifically designed and manufactured with the intention
of being incorporated into food to fulfil a particular function.
It is nevertheless important to note that nanomaterials are widely
found in the natural world and foods will naturally contain nanoscale
structures, including individual macromolecules, micelles and
crystals. For example, a molecule of haemoglobin is about 5.5 nanometres
in diameter, and milk contains micelles ranging from 50 to
500 nm in diameter.
Nanotechnologies can also be applied indirectly
to food manufacture, for example through the development of improved
surfaces for food preparation and for food transport in factories,
or rapid diagnostic tests for contaminants or pathogens in food.
This type of application would not directly affect the properties
of the final product but could lead to improved efficiency and
improved quality control. The remainder of this document focuses
on the use of engineered nanomaterials in food and in food contact
In order to understand better how nanotechnologies
might be applied to food, the FSA recently commissioned two research
projects covering food additives and ingredients, and food contact
materials. Both projects were undertaken by a panel of experts
from the Safety of Nanomaterials Interdisciplinary Research Centre
(SnIRC), led by the Central Science Laboratory (CSL). These projects
collected information on current and future applications of nanotechnologies,
considered the potential implications for consumer safety and
assessed of the regulatory position. In addition, the project
on food contact materials included experimental work on the potential
migration of nanoparticles from two types of food container. The
project reports are being published on the Agency's website and
are attached as Appendices 1 and 2 respectively. The
findings from this research are mentioned in the relevant sections
A. STATE OF
The FSA-funded research project on food additives
and ingredients identified a number of potential applications
of nanotechnology in these areas including nano-sized carriers
for nutrients and other food supplements, nano-sized or nano-encapsulated
food additives, and nanostructured food ingredients. Practical
examples included nutritional supplements, nutraceuticals and
a small number of food ingredients and food additives.
The parallel project on food contact materials
identified a range of potential applications including barrier
layers to improve packaging properties, active antimicrobial or
oxygen scavenging materials to extend shelf life, intelligent
nanosensors to monitor time/temperature storage conditions and
biodegradable polymer-nanomaterial composites. The researchers
concluded that future applications in this area are most likely
to relate to antimicrobial activity or improved barrier properties.
Current market (UK, EU and non-EU)
At least two global inventories exist and these
provide some information on some of the types and numbers of nano-derived
products that may be on the global market across a range of areas,
including food. The Woodrow Wilson Centre's global inventory is
published on the Internet,
as is an inventory of nanoproducts constructed by Friends of the
Both registers list several dozens of "food" products
that have been identified However, it should be noted that Friends
of the Earth's register includes materials with a particle size
greater than 100 nm, which do not fit the common definition
of "nanomaterial". Also, the registers are largely based
on marketing information, which may or may not accurately reflect
what is actually on the market.
At present, it is not possible to provide a
definitive list of nanofoods and nanoscale food contact materials
on the EU market, primarily because of the absence of an EU-wide
register or inventory. The Food Standards Agency is currently
considering various options for developing a UK-based register
of nano-derived foods and food contact materials. The European
Commission has stated that it will begin work on an EU inventory
of nanomaterials during 2009 (see Section C).
According to the European Food Safety Authority's
(EFSA) recent opinion on nanotechnologies,
most nanotechnology applications for food and beverages in the
EU are currently at the research and development stage or near
market stage and have not reached the EU market as yet. The only
UK exceptions known to the Agency are
colloidal silver in the form of food
supplements (an aqueous colloidal suspension of particles of silver
with an average size of 0.8 nm in purified water, also known
as "silver hydrosol"). There are claims that such products
may fight infections and enhance the immune system. Silver hydrosol
has recently been evaluated by EFSA in the context of establishing
an EU list of authorised sources of vitamins and minerals for
use in food supplements. As there was insufficient information
to complete the assessment, this product is unlikely to be included
in the eventual list of approved mineral sources that will come
into effect on 1 January 2010, in which case its continued
use will not be permitted.
food supplements comprising a nano-sized
formulation of co-enzyme Q10 (micelles of approximately 30 nm
diameter). It is claimed that co-enzyme Q10 is an antioxidant
with the nano formulation apparently improving bioavailability
when compared with powdered co-enzyme Q10 or oil-based formulations.
The co-enzyme Q10 product was launched in 2006 and is
manufactured in Germany. The German authorities have concluded
that this type of formulation does not fall within the scope of
the novel foods regulation (see Section C below), as the process
for producing the micelles does not lead to a significant change
in the properties of the active component.
The FSA-funded project on food contact materials
revealed that little was available on the UK or EU markets. Most
products were found on the American and Asian markets although
some could be sourced by UK purchasers via the Internet.
B. HEALTH AND
Approaches to the risk assessment of nanomaterials
have been reviewed by a number of national and International advisory
committees. In the UK the Committees on Toxicity, Mutagenicity
and Carcinogenicity of Chemicals in Food, Consumer Products and
the Environment (COT, COM and COC) produced a joint statement
on nanomaterial toxicology in 2005. The COT produced an addendum
in 2007 following a review of healthcare nanoparticles.
The 2005 statement (attached at Appendix
3) provided a baseline review of the available toxicity data and
outlined the risk assessment approach the Committees would use
for the risk assessment of nanomaterials, including those in food
and feed. They concluded that conventional toxicological assessment
should be sufficient to identify toxic hazards from nanomaterials
provided studies were designed based on the properties of the
nanomaterial under investigation. Whilst the standard toxicological
test batteries would detect possible effects from nanomaterials,
there was as yet, insufficient information to exclude the possibility
of effects not detectable by these methods. Although in 2007 the
COT was not currently aware of such effects being reported.
The 2007 addendum to this statement (Appendix
4) concluded that biodegradable and non-biodegradable nanoparticles
require a different risk assessment approach, since biodegradable
particles are less likely to have toxicity intrinsic to their
In the European Union, the Scientific Committee
on Emerging and Newly Identified Health Risks (SCHENIR) has recommended
strategies for the risk assessment of nanomaterials in 2006 and
Although there are some differences in emphasis due to the questions
being addressed and the remit of SCHENIR, the strategy is consistent
with that of the UK advisory committees.
In March 2009 the Scientific Committee
of the European Food Safety Authority published its opinion on
the risk assessment of engineered nanomaterials, specifically
in relation to food and in animal feed The Scientific Committee
also agreed that the general risk assessment paradigm (hazard
identification, hazard characterization, exposure assessment and
risk characterization) can also be applied to the risk assessment
of engineered nanomaterials in the food and feed area. The risk
assessment of engineered nanomaterials has to be performed on
a case-by-case basis and needs to consider the specific properties
of nanomaterials in addition to those common to the equivalent
non-nano forms of the same chemical substance.
There is currently limited information in several
areas which leads to uncertainties in the risk assessment of nanotechnologies
and their possible applications in the food and feed area. Specifically
there are difficulties in characterising, detecting and measuring
engineered nanomaterials in food, feed and biological matrices.
This limits the ability to assess actual exposure from possible
applications and products in the food and feed area. There is
limited data on oral exposure to specific nanomaterials and any
consequent toxicity; the majority of the available information
on toxicity of nanomaterials is from, in vitro studies
or from, in vivo studies using other routes of exposure.
These limitations in the database need to be reflected as qualitative
and quantitative uncertainties in the risk characterization step
of any risk assessment.
The risk assessment of a nanomaterial in the
food and feed area requires comprehensive identification and characterisation
of the material, information on whether it is likely to be ingested
in nanoform, and, if ingested, whether it remains in nanoform
at the point of absorption. If ingested in nanoform, then repeated-dose
toxicity studies on the nanomaterial are needed together with
appropriate, in vitro studies (eg for genotoxicity).
FSA Funded research
The FSA-funded projects, mentioned above, included
an assessment of implications for consumer safety and these reports
are consistent with the EFSA opinion. The researchers also highlighted
several gaps in knowledge and recommended further research into
the physico-chemical properties, behaviour, fate and effects of
nanomaterials used in food applications,.
The project on food contact materials included
tests on migration of nanoparticles from two typical materials
made of nanomaterial-polymer composites (nanoclay and nanosilver).
The results showed no detectable migration from the polymer composite
consisting of nanoclay embedded between PET (polyethylene terephthalate)
layers and a very low level of migration of silver from food containers
consisting of polypropylene-nanosilver composite. In both cases,
the presence of nanoparticles did not affect the migration of
other (non-nano) components. The study provided some reassurance
in the safety of nanotechnology-derived food contact materials
but nonetheless demonstrated that migration is likely to be dependent
on the type and composition of the polymer.
The Nanotechnology Research Coordination Group
(NRCG) was set up in 2005 to coordinate publicly funded research
into the potential risks presented by the products and applications
of nanotechnologies. Defra chairs this Group and the membership
includes Government Departments (including the Food Standards
Agency), Regulatory Agencies and the Research Councils. NRCG has
three main aims.
to develop and oversee the implementation
of a cross-Government research programme into the potential human
health and environmental risks posed by free manufactured nanoparticles
and nanotubes to inform regulation and underpin regulatory standards.
to establish links in Europe and internationally
to promote dialogue and to draw upon and facilitate exchange of
information relevant to the Group's research objectives.
to consider the outputs of dialogue between
stakeholders, researchers and the public (as integrated with the
NIDG's wider plans for stakeholder and public dialogue) with a
view to enhancing and informing research decisions.
The NRCG began by identifying a programme of
19 research objectives aimed at characterising the potential
risks posed by engineered nanoscale materials.
NRCG published progress reports in 2006 and 2007 that
provide an overview of the work that has been commissioned in
pursuit of these objectives.
Work in these areas is primarily funded by the Research Councils
under their standard procedures for commissioning research. As
noted above, the FSA has commissioned two reviews covering food
additives and ingredients, and food contact materials.
The FSA has conducted a review to identify potential
gaps in regulations relating to the use of nanotechnologies in
the food sector. The review was published in August 2008 (Appendix
5). The main areas covered were food ingredients, food additives
and food contact materials.
No major gaps in legislation were identified
by this review and, on the basis of current information; it was
found that most potential uses of nanotechnologies that could
affect food would require some form of approval process before
being permitted for use. Manufactured nano-derived ingredients,
additives and food contact materials will be captured by the general
safety requirements of the EU Food Law Regulation (Regulation
(EC) 178/2002), which requires that food placed on the market
is not unsafe. Additionally, more specific legislation exists
in three major areas that cover all the likely applications leading
to engineered nanomaterials being present in food:
(i) novel foods and food ingredients
The European regulation on novel foods (Regulation
(EC) 258/97) applies to foods and food ingredients (other than
food additives) that were not consumed in the EU prior to 15 May
1997. It establishes a mandatory pre-market approval system for
all novel foods and processes and is legally binding across all
27 EU Member States. Nanoparticulate forms of a food ingredient
that has a history of use will also require authorisation under
the novel foods Regulation due to the difference in the production
process employed, if the net result is that the nanoparticles
have different properties to the existing ingredient.
In January 2008 the European Commission
published a proposal to revise and update the 1997 regulation.
The European Parliament has proposed that any new regulation should
explicitly apply to all nanomaterials, in order to eliminate any
doubt as to their status under this legislation. This proposal
is still under discussion by Member States and the European Parliament
Nano-derived additives are considered within
the scope of Food additives legislation. Food additives are controlled
in the UK by the Sweeteners in Food Regulations 1995 (as
amended), the Colours in Food Regulations 1995 (as amended),
and the Miscellaneous Food Additives Regulations 1995 (as
amended), with smoke flavourings being specifically controlled
by the Smoke Flavourings (England) Regulations 2005. A recently
agreed amendment to food additives legislation specifies that
where an existing food additive is produced through nanotechnology,
it should be assessed by EFSA as a new additive.
(iii) food contact materials
Migration of nanocomponents into food from,
for example, packaging would be considered in the scope of Regulation
(EC) 1935/2004, which provides the overall framework for the regulation
of food contact materials. Provision exists for the Commission
or Member States to request the EFSA to conduct an independent,
expert human health risk assessment of any substance or compound
used in the manufacture of a food contact material/article. Specific
materials such as plastics are subject to additional measures
and within these measures it is possible for a nanomaterial to
be treated separately from the normal scale substance from which
it is derived. It would therefore be possible for a nanocomponent
to be authorised only following a risk assessment by the EFSA.
The regulation of nanoscale substances in food contact plastics
is currently being clarified in preparation for an updated European
regulation, and the European Commission has proposed that any
substance with a deliberately altered particle size should not
be used, even behind a specific migration barrier, without a specific
EU legislation on animal feed covers the additives
(vitamins, colourants, flavourings, binders, and so on) authorised
for use in animal feed; the maximum levels of various contaminants
(eg arsenic, lead, dioxins); ingredients that may not be used
in feed; nutritional claims that can be made for certain feeds;
the names and descriptions which must be applied to various feed
materials; and the information to be provided on feed labels.
The Agency is not aware of any specific applications
in the pipeline with respect to the use of nanotechnology directly
in animal feed. However, current procedures would allow a proper
risk assessment to be performed on such products if and when they
appear, including the manufacture of currently authorised additives
and bioproteins by new methods.
Food imported from countries outside the EU
can only be marketed if it meets food safety and food standards
requirements that are at least equivalent to those for food produced
in the UK and elsewhere in the EU. Food businesses are legally
responsible for ensuring the food they import complies with these
requirements, and UK enforcement authorities have powers under
food safety legislation to check all imported food for compliance.
However, food products ordered from a non-EU
country by members of the public in limited quantities for their
personal use, for example over the Internet, may not be subject
to the protection of UK food safety requirements.
At EU level, DG SANCO
organised a workshop in October 2008, the second Nanotechnology
Safety for Success Dialogue, which provided a platform for presentations
and discussions between relevant stakeholders in the nanotechnologies
field, including industry, academia, NGOs, Government departments
and Commission Officials. The Director General of DG SANCO subsequently
identified 10 priority actions to address the key points raised
during the workshop (listed in Appendix 6), grouped under the
following headings: dialogue and governance, market intelligence,
scientific knowledge and gap filling; and risk assessment and
guidance. Several of these action points will encompass applications
of nanotechnologies in the food area and will involve collaboration
between EU Member States and the Commission.
The Organisation for Economic Cooperation and
Development also provides a forum for international co-operation
on nanomaterials through its Working Parties on Manufactured Nanomaterials
and on Nanotechnology, although these are not specific to food
and its current risk assessment projects are focussed on materials
with no direct food connection, such as carbon nanotubes and cerium
The Swiss-based International Risk Governance
Council (IRGC) recently completed a report on nanotechnology applications
in food and cosmetics,
which included a discussion of regulatory approaches in the USA,
Europe and Japan. IGRC noted that the regulatory responses to
nanotechnology have been similar in each of these jurisdictions,
in that existing regulations are thought to be adequate sufficient
to cover nanoscaled materials in general. In each case, however,
questions have been raised about the adequacy of current test
methods and the ability of regulatory bodies to monitor and control
measurements and risk assessments.
D. PUBLIC ENGAGEMENT
In late 2008 the Food Standards Agency
commissioned an evidence review in relation to public attitudes
to emerging food technologies, including nanotechnologies. The
report of this review is expected to be published in March 2009.
The main findings in relation to previous studies on attitudes
to nanotechnologies were as follows:
Awareness of nanotechnology is low, particularly
in relation to food.
Although general attitudes towards nanotechnologies
seem fairly positive, attitudes towards its use in food are less
positive. Whilst people are concerned about the risks of nanotechnology
in all its forms, they seem less convinced about the potential
benefits of food applications than other uses and are sceptical
about why these are being developed.
In general, use of nanotechnology in
food packaging may be seen more positively than its use in food.
Concerns about nanotechnology, in
general include effectiveness, long-term side-effects and
the ability of regulators and others to ensure safety and to ensure
that developments benefit the general public.
Other factors affecting attitudes towards
nanotechnology, which are often better predictors than socio-demographics,
include their scientific knowledge (eg experience of previous
technological innovations), their general outlook/worldview and
where they have received information from (people are more positive
towards sources deemed to share a similar view point to them).
The review uncovered no evidence of how
people's views on nanotechnology affect their food behaviour or
choices, mainly due to lack of food products on the market.
The review highlighted that nanotechnology
is an extremely active area of research which will be covered
under FP7 (The Seventh Framework Programme (FP7) combines
all research related EU initiatives, it is a key pillar of the
European Research Area) but at the time of writing, awards were
still pending. Research in the pipeline included looking at how
consumers weigh up the risks and benefits of the technology and
the psychological underpinning of differing attitudes.
Effective engagement and public information
The evidence review identified a consensus form
the existing body of work that public opinion is in the process
of being formed and there was little information currently available
to the public on which they can formulate their views.
Future public engagement
As the issues arising from the breadth of nanotechnologies
and nanomaterials are complex, more time and resources need to
be provided for the public to learn and understand the pros and
cons in terms of any consumer or societal benefits and any potential
risks. Developing a range of engagement activities to engage the
public rather than using a "one size fits all" approach
will ensure that a wider spectrum of the public are provided with
an opportunity to be involved.
Any materials provided for the public need to
be prepared with the public in mind ie in plain English.
Lessons learned from engagement
Effective engagement needs to developed upstream
of any important decision making. The public should be involved
in the framing of the discussion so that their questions are answered.
As an example, the FSA commissioned research on cloned animals
in 2007-2008, which took the form of reconvened workshops with
the general public across the UK. This showed that the public
were less concerned with how the technologies and science work,
and their focus was on the 'why' and what the consequences may
be. This was closely connected to the drivers behind the development
and a perception that the motives were about increasing profit
above other factors.
Good public engagement needs to be based on
more than just scientific evidence and needs to take account of
wider societal issues ie environmental, ethical, moral and economic.
The worldview that consumers' hold and the channel used to provide
information is as important as the content.
Some issues, like nanotechnology, are not on
everyone's radar and are not part of their everyday life. To engage
effectively the subject should be brought to life and the public
need to see the relevance to their lives. Bringing scientists
and the public together in the same room and talking on the same
level can foster good relationships and can have a positive effect
on the outcome.
Good public engagement will have feedback built
in at the planning stage. It is good practice to let people know
how their input has made a difference. This need not be more complicated
than sending an email or updating websites.
A fundamental principle of food labelling legislation
is that consumers should be provided with sufficient information
to make informed choices about the foods that they eat. Information
must, by law, be clear and not misleading. There is also a limit
to the amount of information that can sensibly be provided on
a food label.
Recognising these conflicting requirements,
it is necessary when defining mandatory labelling requirements
to give priority to items that are important for the safe use
of the food, while ensuring that any additional labelling requirements
are balanced and proportionate. Any demands for special labelling
of "nanofoods" would have to be viewed against this
background. At present we do not have information about whether
UK consumers would value information on the use of nanotechnology
in food production, and what sort of information would meet the
necessary criteria of clarity and comprehension.
Defra, 2005. Characterising the potential risks
posed by engineered nanoparticles: A first UK Government research
Defra, 2006. Characterising the potential risks
posed by engineered nanoparticles: UK Government researcha
progress report (October 2006). http://www.defra.gov.uk/environment/nanotech/research/reports
Defra, 2007. Characterising the potential risks
posed by engineered nanoparticles: A second UK Government research
report (December 2007). http://www.defra.gov.uk/environment/nanotech/research/reports
EFSA, 2009The Potential Risks Arising
from Nanoscience and Nanotechnologies on Food and Feed Safety
Friends of the Earth, 2008. Report"Out
of the laboratory and on to our plates: Nanotechnology in food
and agriculture" (March 2008) http://www.foeeurope.org/activities/nanotechnology/index.htm
IGRC, September 2008 (International Risk
Governance Council) "Risk Governance of Nanotechnology Applications
in Food and Cosmetics": http://www.irgc.org/Nanotechnology.html
SCENIHR, 2006 (Scientific Committee on
Emerging and Newly Identified Health Risks), 10 March 2006,
modified opinion on: The appropriateness of existing methodologies
to assess the potential risks associated with engineered and adventitious
products of nanotechnologies http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_003b.pdf
SCENIHR, 2007a (Scientific Committee on Emerging
or Newly-Identified Health Risks), 21-22 June 2007, The Appropriateness
of the Risk Assessment Methodology in Accordance with the Technical
Guidance Documents for New and Existing Substances for Assessing
the Risks of Nanomaterials, at http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_010.pdf
SCENIHR, 2007b (Scientific Committee on Emerging
and Newly Identified Health Risks), 29 November 2007, Opinion
on the scientific aspects of the existing and proposed definitions
relation to products of nanoscience and nanotechnologies, at http://ec.europa.eu/health/ph_risk/committees/04_scenihr/docs/scenihr_o_012.pdf
Woodrow Wilson Center, Project on Emerging Nanotechnologies:
An inventory of nanotechnology-based consumer products currently
on the market. Available online at: http://www.nanotechproject.org/inventories/consumer/
1. Food Standards Agency research project A01057:
Assessment of the potential use of nanomaterials as food additives
or food ingredients in relation to consumer safety and implication
for regulatory controls. (July 2007)
2. Food Standards Agency research report A03063:
Assessment of current and projected applications of nanotechnology
for food contact materials in relation to consumer safety and
regulatory implications. (July 2008)
3. COT, 2005. UK Committees on toxicity, mutagenicity
and carcinogenicity of chemicals in food, consumer products and
the environment (COT, COM, COC). Joint statement on nanomaterial
4. COT, 2007. UK Committee on toxicity, of chemicals
in food, consumer products and the environment. COT Addendum to
joint statement of the Committees on toxicity, mutagenicity and
carcinogenicity of nanomaterial toxicology. COT Statement 2007/01,
March 2007. http://cot.food.gov.uk/pdfs/cotstatementnanomats200701.pdf
5. Report of FSA regulatory review of potential
implications of nanotechnologies for regulations and risk assessment
in relation to food. (August 2008). http://www.food.gov.uk/multimedia/pdfs/nanoregreviewreport.pdf
6. Letter from Robert Madelin (Director General
for Health and Consumers, European Commission). Follow-up to the
second Nanotechnology Safety for Success DialogueTop 10
actions to take by Easter 2009. (December 2008)
12 March 2009
2 Bioavailability: the extent to which a substance
can reach the systemic blood circulation and its availability
at the site of action, when taken orally. Back
BSI Publicly Available Specification "Vocabulary - nanoparticles"
(May 2005). PAS 71:2005 Back
Note: The International Standards Organisation uses the term "nano-object"
to refer to a discrete object with one or more external dimensions
in the nanoscale. In this usage, the term "nanomaterial"
includes material which is larger than the nanoscale but which
is nanostructured-ie it is made up of smaller, nanoscale elements. Back
Woodrow Wilson Center (online inventory) Back
Friends of the Earth (2008) Back
EFSA (2009) Back
SCENHIR (2006, 2007a, 2007b) Back
Defra (2005) Back
Defra (2006, 2007) Back
The applicability of UK legislation will depend on issues such
as where the contract between the seller and purchaser is made. Back
DG SANCO: the European Commission's Directorate General for Health
and Consumers Back
IRGC 2008 Back