The International Food Additives Council (IFAC) is a global association representing manufacturers and users of food ingredients. IFAC is committed to ensuring the safety of its members’ products as well as communicating technical information about ingredients in foods.
A term that is sometimes linked to food is nanotechnology, and is often accompanied by words such as “nanoparticles” or just “nano”. Nanotechnology refers to the study and control of matter at an incredibly small scale, generally between 1 and 100 nanometers, and is not well understood by consumers. Although particle size is not commonly considered in the context of food, many foods, beverages and even water are naturally comprised of nanoscale particles. For example, milk is an emulsion of nanoscale fat droplets. While nanoscale particles have always been present in foods and beverages, food scientists have developed technologies to engineer nanomaterials in order to support improvements in the food and beverage industry. Nanotechnology has allowed for advancements such as more protective food packaging materials and increased availability of beneficial nutrients in foods.
As with any new technology, questions have been raised about the need to assess the potential impact of nanoparticles on health, safety and the environment. Global scientific and regulatory agencies are therefore reviewing information and data on nanotechnology and several guidance documents have already been published by the US Food and Drug Administration (FDA), the US Environmental Protection Agency (EPA) and the European Food Safety Authority (EFSA).
IFAC strongly believes that the safety of food ingredients depends on the specific substance in question, and should not be determined based solely on its particle size. In addition, industry’s innovative use of nanotechnology should not impact the credibility of safety assessments for ingredients already on the market, which have a significant history of safe use. To ensure transparency and prevent confusion among consumers and other audiences, it is important to distinguish products with a history of safe use from new ingredients or applications utilizing nanotechnology which have not undergone the same level of safety testing. IFAC believes that clearly defining nanotechnology for industry and consumers is a first step in doing so. Therefore, IFAC urges regulators and scientific communicators to clearly specify that nanotechnology refers to the human engineering of particles in order to create matter smaller than 100 nanometers. As the European Union (EU) describes in Article 3(2) of Regulation (EU) No 2015/2283, engineered nanomaterials are defined as “any intentionally produced material that has one or more dimensions of the order of 100 nm or less or that is composed of discrete functional parts, either internally or at the surface…” Nanotechnology should not be used interchangeably with nanoparticles or the generic term “nano,” which includes particles of nanoscale dimensions that occur naturally and/or are not necessarily produced through new forms of nanotechnology. In addition, it is important that government labeling and industry sourcing policies serve to address newly engineered nanomaterials, so as not to proliferate irrational fear amongst consumers concerning the foods and beverages they have historically consumed.
IFAC strongly believes it is critical that all food ingredients and food contact materials undergo extensive safety testing prior to entering the food supply. IFAC supports the existing FDA regulatory framework for determining the safety of food additives, GRAS substances and food contact materials, as well as the European Commission’s food additive re-evaluation mandate. Such regulatory requirements ensure all foods and beverages on the market, including those manufactured using nanotechnology, are safe. In addition, while IFAC firmly supports clear, fact-based communications regarding nanotechnology, we also believe that the freedom to innovate through the use of advanced technologies is essential to respond to consumer demand, improve products and processes, and ultimately feed the growing global population.
The ability to innovate while continuing to comply with new and existing strict safety requirements is in line with the U.S. Food and Drug Administration’s (FDA) approach to be “adaptive and flexible and to take into consideration the specific characteristics and the effects of nanomaterials in the particular biological context of each product and its intended use.” Therefore, as innovative processes allow for the engineering of food ingredients and materials reduced to nanoscale, potential safety issues need to be assessed on a case by case basis. FDA has provided specific guidance to industry on the potential impact of significant manufacturing process changes involving nanotechnology on the safety and regulatory status of food substances.
IFAC believes it is the responsibility of both industry and regulators to develop responsible policies and guidance around the definition, labeling requirements, and industry use of nanotechnology. As with all novel ingredients, approvals and opinions intended to inform new standards or regulations should be based on the unbiased assessment of strong peer-reviewed research and stakeholder input.