What are botanicals and can you talk about them to consumers?
11th August 2022
Written by HRS Communications
What are botanicals?
Botanicals are defined by the National Institute of Health as ‘a plant or plant part, valued for its medicinal or therapeutic properties, flavour and/or scent’ 1. You may have heard of common botanicals such as chamomile, turmeric and rosemary.
Botanicals can be prepared in several ways for consumer use e.g., extracts, infusions and teas. Botanicals are often used as food ingredients² or they may have ingredients extracted from them for use e.g., flavonoids³.
Botanicals and Nutrition and Health Claims
There is no centralised authorisation procedure for the use of botanicals and derived preparations in foods. Nonetheless, the use of botanicals and derived preparations in food must comply with the general principles and requirements of food law in the UK. This assigns primary legal responsibility for the safety of the products placed on the market to business operators.
The On-Hold Register
The EFSA Article 13.1 On-Hold Register (which has post BREXIT been adopted by the UK) lists claims for botanicals in foods that have been reviewed but to date have neither been authorised, nor rejected, hence they are called On-Hold Claims. There are around 2000 claims for botanicals substances that remain on-hold since 2012. In theory these On-Hold Claims can be used if the manufacturer can supply evidence to support the levels in the final product.
Conditions of Use
Conditions of use are usually available in the original claim that was submitted to EFSA for review; these can be used as scientific justification for the claim. Ultimately, the manufacturing company must provide sufficient scientific evidence to substantiate any claims made and the quantities used in the product. Because these claims are somewhat in limbo, while they can be used, there is always a risk, as the status of the claims may change – they could be rejected formally and no longer be valid to use in the marketplace.
For example, a permitted claim which can be used for the ingredient ginger is ‘helps to support digestion’. The conditions for use for this claim are 0.5-2g/day of root ginger.
How can HRS help?
Our highly experienced industry Dietitians and Nutritionists can review your product range and/or support with product formulation to maximise your claims opportunities. These claims would all be authorised for use under the EU/ GB Nutrition and Health Claim and On-Hold EFSA registers.
Where you’re not able to make a permitted health claim, HRS can provide you with suggested statements that describe the ingredients included. These statements are not health claims and so are not regulated*.
*Context is important in branded consumer communications, so final approval is necessary to ensure compliance and spirit of the legislation is upheld.
- National Institutes of Health Office of Dietary Supplements (2020) Botanical Dietary Supplements – Background Information [online] Available at: https://ods.od.nih.gov/factsheets/BotanicalBackground-Consumer/ [Accessed: 23 June 2021]
- Anton R, Serafini M, Delmulle L. (2014) Traditional Botanical Preparations and Health Benefits: The Key Concept of History of Use, European Food and Feed Law Review. 9(6):391-398. Available at: https://www.jstor.org/stable/24326136 [Accessed: 23 June 2021]
- Coppens P, Delmulle L, Gulati O, Richardson D, Ruthsatz M, Sievers H et al. (2006) Use of Botanicals in Food Supplements. Annals of Nutrition and Metabolism. 50(6):538-554. Available at: https://doi.org/10.1159/000098146 [Accessed: 23 June 2021]