Many have been awaiting this eagerly. Since 1.7.2020, maximum quantity limits no longer apply to some vitamins and one mineral. What are the implications for product development? Is it now permissible to have discretionary quantities in food supplements? - Unfortunately NOT!
The maximum levels specified in the Swiss ordinance governing food supplements (VNem) are exclusively based on the purpose of food safety. By creating VNem Appendix 1, the authorities have conducted food safety assessment for the industry. However, it is still the responsibility of each individual company to remain within the intended function of a food supplement for each individual product and to comply with its obligation to protect against misleading. Can quantities that are 20,000% or 30,000% of the Nutrient Reference Value (NRV) still represent a normal supplement to diet? For healthy people? In a situation of increased need? For maintaining normal homeostasis? Hardly! Even in situations of increased need, such as pregnancy, elite sport, or special types of diet such as veganism, healthy people never require such high quantities to maintain normal body function. As such, the intended function of the product is in such cases outside the scope of a food supplement, and companies would be guilty of misleading, as statements about dietary supplements must be true and clear.
In concrete terms, this means that for each of your products you must demonstrate legitimacy, on the one hand based on scientific principles (pharmacological vs. dietary effect) and on the other hand based on an estimate of the potential for misleading, and you must also document this within the context of self-monitoring.