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26 March 2002:

Dear Ombudsman,

As per my communication with Murielle Richardson below, I hereby write again
to you at this address (as given om your web site - which is indeed the same
address I have used before), to file a formal complaint about the EU Food
Supplement Directive, as a case of maladministration.

The EU commission failed to accomplish - and release - A Small and Medium
Enterprise impact study in conjunction with the EU Food Supplement
Directive. I believe this is both a case of maladministration and possibly a
case of willful oversight. It has, after all, been brought to the attention
of Commissioner Byrne, by Caroline Jackson MEP UK.

I also propose that the Food Supplement Directive, although it deals with
"food", has a possibly severe impact on the health of all EU citizens, and
the developement of nutritional/orthomolecular "medicine" - and therefor
must be considered as health legislation. The EU, untill the Treaty of nice
has been ratified, has no right to legislate in health matters, as i
understand it. I would classify this aspect also as maladministration, in
that the effect of the directive is on health, primarily, while it is
treated as food related (which it is too, of course).

Thirdly, the fact that a directive is approved and implemented before the
content is established, as in this case regarding the not yet worked-out
dose recommendations from the SCF (who are known to be exceedingly
conservative), must also be considered maladministration - if not outright

Lastly the directive is purporting, in its text, to "protect the safety of
the consumer". Since then, the EU commission has admitted that it is only
concerned with the trade aspect (according to Rapporteur at the end of
february: "The European Commission last week undermined the position of
most EU consumer associations by admitting that the Food Supplements
Directive is based on single market rather than health concerns.")Thus I
charge, that they have been unfair to the consumer, and been untruthful in
the formulation of the intent of the directive.

I write on behalf of the Norwegian Consumer organization Fritt Helsevalg
(Free Health Choice), and although Norway is not an EU member, we will, as
you are aware, be impacted by such a directive just as we would if we were a

I urge you, Mr. Ombudsmann, to consider the directive in light of the above,
as it, in our view, clearly constitutes "maladministration", in the form of
unfairness (to the largely uninformed consumer), discrimination (re health
freedom choice) and administrative irregularities (as in the lack of SME
impact Study, and attempting to legislate in what is clearly a health
matter, before the Treaty of Nice has been ratified.)

Jan Klyve
Fritt helsevalg