by Brandon Turbeville

Excerpt from Codex Alimentarius - The End of Health Freedom

from ActivistPost Website

German version


Brandon Turbeville is an author out of Mullins, South Carolina.

He has a Bachelor’s Degree from Francis Marion University where he earned the Pee Dee Electric Scholar’s Award as an undergraduate.

He has had numerous articles published dealing with a wide variety of subjects including health, economics, and civil liberties.

He is also the author of

Codex Alimentarius - The End of Health Freedom







Part 1

Codex Alimentarius

November 17, 2010




Contrary to popular belief Codex Alimentarius is neither a law nor a policy.


It is in fact a functioning body, a Commission, created by the Food and Agricultural Organization and the World Health Organization under the direction of the United Nations. The confusion in this regard is largely due to statements made by many critics referring to the “implementation” of Codex Alimentarius as if it were legislation waiting to come into effect.


A more accurate phrase would be the “implementation of Codex Alimentarius guidelines,” as it would more adequately describe the situation.

Codex is merely another tool in the chest of an elite group of individuals whose goal is to create a one world government in which they wield complete control. Power over the food supply is essential in order to achieve this. As will be discussed later, Codex Alimentarius will be “implemented” whenever guidelines are established and national governments begin to arrange their domestic laws in accordance with the standards set by the organization.

The existence of Codex Alimentarius as a policy-making body has roots going back over a hundred years.


The name itself, Codex Alimentarius, is Latin for “food code” [1] and directly descended from the Codex Alimentarius Austriacus, a set of standards and descriptions of a variety of foods in the Austria-Hungarian Empire between 1897 and 1911.[2]


This set of standards was the brainchild of both the food industry and academia and was used by the courts in order to determine food identity in a legal fashion.

Even as far back as 1897, nations were being pushed toward harmonization of national laws into an international set of standards that would reduce the “barriers to trade” created by differences in national laws.[3]


As the Codex Alimentarius Austriacus gained steam in its localized area, the idea of having a single set of standards for all of Europe began to pick up steam as well.


From 1954-1958, Austria successfully pursued the creation of the Codex Alimentarius Europaeus (the European Codex Alimentarius). Almost immediately the UN directed FAO (Food and Agricultural Organization) sprang into action when the FAO Regional Conference for Europe expressed the desire for a global international set of standards for food.


The FAO Regional Conference then sent a proposal up the chain of command to the FAO itself with the suggestion to create a joint FAO/WHO program dealing with food standards.

The very next year, the Codex Alimentarius Europeaus adopted a resolution that its work on food standards be taken over by the FAO.


In 1961, it was decided by,

  • the WHO

  • Codex Alimentarius Europaeus

  • Organization for Economic Co-operation and Development (OECD)

  • the FAO Conference, create an international food standards program known as the Codex Alimentarius.[4]


In 1963, as a result of the resolutions passed by these organizations two years earlier, Codex Alimentarius was officially created.[5]

Although created under the auspices of the FAO and the WHO, there is some controversy regarding individuals who may or may not have participated in the establishment of Codex. Many anti-Codex organizations have asserted that Nazi war criminals, Fritz Ter Meer [6] and Hermann Schmitz [7] in particular, were principal architects of the organization.


Because many of these claims are made with only indirect evidence, or no evidence at all, one might be tempted to disregard them at first glance. However, as the allegations gain more and more adherents, Codex has attempted to refute them.


In its Frequently Asked Questions section, Codex answers the question,

“Is it true that Codex was created by a former war criminal to control the world food supply?” [8] 

It then goes on to answer the charges by stating:

No. It is a false claim. You just need to type the words "Codex Alimentarius" in any search engine and you will find lots of these rumors about Codex. Usually the people spreading them will give no proof but will ask you to send donations or to sign petitions against Codex.

Truthful information about Codex is found on the Internet - there is nothing to hide from our side - we are a public institution working in public for the public - we are happy if people want to know more about our work and ask questions. There is an official Codex Contact Point in each member country who will be pleased to answer your questions on Codex.[9]

But, as one can see from the statement above, Codex’s response does very little to answer this question beyond simply disagreeing with it.


While it is true that many individuals who make this claim provide little evidence for it, the presentation of the information does not necessarily negate its truthfulness.


In fact, Codex offers its own website as a source for accurate information about the organization; yet, beyond the FAQ section, there is nothing to be found that is relevant to the “war criminal” allegations. Furthermore, the website is virtually indecipherable, almost to the point of being completely useless. In the end, this response raises more questions than it answers.


This is because Codex, if it wanted, could put these rumors to rest by simply posting a list of the individuals and organizations that funded or played an integral role in its creation. However, it does nothing of the sort. Beyond mentioning the FAO and the WHO, we are completely unaware of who or how many other individuals and organizations participated in the creation of Codex Alimentarius.

The “war criminal” claims center around the chemical conglomerate known as I.G. Farben.


I.G. Farben was made up of several German chemical firms including,

  • BASF

  • Bayer

  • Hoechst

  • AGFA,[10]

...that merged together.


It was essentially the manufacturing wing of the Third Reich and was the engine behind the Nazi war machine.


The company provided the vast majority of explosives and synthetic gasoline used for the military conquest and murder of millions.


It also manufactured the now infamous Zyklon-B gas used in the gas chambers. Not only that, but it was influential in the conducting of experiments on concentration camp victims. Indeed, camp victims were often purchased outright at the behest of the company for the express purposes of testing by several different branches of the company, particularly Bayer and Hoechst.

Without I.G. Farben, the German wars simply could not have been sustained.


During the Nuremberg war trials, the tribunal convicted 24 board members and executives of the company and dissolved it into several different daughter companies. Namely, BASF, Hoechst (later to be known as Aventis), and Bayer. By 1951, virtually all 24 of these executives were released, including Fritz Ter Meer and Hermann Schmitz.


Ter Meer had been a member of the I.G. Farben executive committee from 1926-1945 and also a member of the working committee and the technical committee as well as a director of the infamous Section II. He was also the ambassador to Italy given full power by the Reich Minister for armaments and war production and was the industrialist most responsible for Auschwitz. Schmitz was also a member of the I.G. Farben executive committee from 1926-1935, and was chairman of the board and “head of finances” from 1935-1945.


He was also head of military economics and a member of the Nazi party. Both men were found guilty by the Nuremberg war tribunal in 1948, yet Schmitz was released in 1950 and Ter Meer in 1952.[11]

After all this, Schmitz was appointed board member of the German bank of Berlin West in 1952 and in 1956, the honorary chairman of the board of Rheinish steel plants. Ter Meer, however, was even more successful. Upon his release, he was appointed board member of Bayer in 1955 and, in 1956 was appointed chairman.


In the years following, he would take on many additional roles such as chairman of the board of Theodore Goldschmidt AG, deputy chairman of the board of Commerzbank and Bank-Association AG, as well as a board member of the Waggonfabrik Uerdingen, Duesseldorger Waggonfabrik AG, the bank association of West Germany, and United Industrial Enterprises AG.[12]


These are documented connections for both of these men. Indeed, Ter Meer’s’ connections to the pharmaceutical firm Bayer earned him a foundation named in his honor, the Fritz Ter-Meer Foundation.[13]


Through all of this however, this writer could not confirm that either Ter Meer or Schmitz had direct connections to the creation of Codex Alimentarius.

However, Codex does nothing to dispel the allegations besides simply disagreeing with them and the connections are not at all implausible. Codex is very secretive about its beginnings, as evidenced on its website where it only states that it was created at the behest of the FAO and the WHO. It is highly unlikely that such an organization would be created without the assistance, input, and even funding of privately owned international corporations.


Thanks to both the anti-Codex community and Codex Alimentarius itself, there is no evidence (again at least to this author) that documents which individuals or corporations were involved in its establishment.


However, there are other ties that lend more credence to the belief that war criminals played a role in the creation of Codex.





[1] Tips, Scott C. “Codex Alimentarius: Global Food Imperialism.” FHR. 2007. P. ii.

[2] “Opening Statement by Dr. B.P. Dutia Assistant Director-General Economic and Social Policy Department, FAO to the Nineteenth Session of the Codex Alimentarius Commission.” Food and Agricultural Organization. July 1, 1991.
See also, Taylor, Paul Anthony. “Codex Guidelines for Vitamins and Minerals - Optional or Mandatory?” Dr.Rath Health Foundation.

[3] “Codex Alimentarius: how it all began.” Food and Agricultural Organization.

[4] “Understanding the Codex Alimentarius.” World Health Organization. Food and Agricultural Organization. 2006. P. 7

[5] Tips, Scott C. “Codex Alimentarius: Global Food Imperialism.” FHR. 2007. P.ii

[6] “The History of the ‘Business With Disease.’” Dr. Rath Health Foundation.

[7] Minton, Barbara. “Codex Threatens Health of Billions.” Naturalnews. July 30, 2009.

[8] “FAQs - Rumours”

[9] Ibid.

[10] Behreandt, Dennis. “The crimes of I.G. Farben: during WWII, I.G. Farben, a synthetic-fuels manufacturer for the German war machine, was a major supporter of the Nazi regime and a willing co-conspirator in the Holocaust.” The New American. November 27, 2006.
See also, “The Documentation About ‘Codex Alimentarius.’” Dr. Rath Health Foundation.

[11] “The History of the ‘Business With Disease.’” Dr. Rath Health Foundation.

[12] Ibid.

[13] Weimbs Lab: Molecular, Cellular and Developmental Biology University of California, Santa Barbra. Dr. Thomas Weimbs received a scholarship from the Fritz ter Meer Foundation in 1988.





Part 2

The Health Tyrants - Codex Alimentarius

November 22, 2010




The health commission of Codex Alimentarius, and the subsequent legislation to come from it, has provable roots to,

  • Nazism

  • Communism

  • eugenics

  • one-world government initiatives

Let's put forth a few of the names and philosophies of the tyrants responsible for this proposed global health tyranny.

I.G. Farben was not isolated to Germany.


Not only were they a conglomerate of Bayer, Hoechst, BASF and other companies, I.G. Farben was also welded to Shell Oil of Britain and Standard Oil and DuPont of the United States by 1929. This occurred after I.G. Farben discovered how to make petroleum out of coal. Subsequently, there was an agreement for I.G. Farben to stay out of the petroleum market if Standard Oil would stay out of the chemical market.[1]

Hermann Schmitz, who was chairman of the board for I.G. Farben, as mentioned above, had a large amount of stock in Standard Oil New Jersey, while the Rockefeller Foundation likewise owned a substantial amount of stock in I.G. Farben.[2]


So much stock that when I.G. Farben’s holdings were completely sold off in 1962, the Rockefellers were the dominant holders involved in the transactions.[3] This is significant because the Rockefeller Foundation and the Rockefeller family in general were major supporters not just of the Nazi regime and eugenics, but the creation of the United Nations.[4]

Indeed, the connections between the Rockefellers and the atrocities of Nazi Germany, Communist Russia, and Communist China are so plentiful as to preclude them from being dealt with in much detail in this article. This evidence is readily available to anyone who wishes to investigate and is made much easier because, in large part, the Rockefellers do not deny it.


In addition to open support for eugenics, the Rockefellers are also committed globalists, again a philosophy which is readily admitted.


The Rockefeller connections to globalist organizations such as, name a few are widely documented and discussed. Indeed, it was John D. Rockefeller that donated the land on which the United Nations headquarters was built.[8]

As one digs deeper and deeper into the history of the United Nations and even the concept of globalization itself, one encounters more and more of the Rockefeller family tree along the way.


It eventually becomes obvious that the Rockefellers, along with other elite families, had a vested interest in the creation of an international governing body as well as a powerful hand in its creation through organizations such as those mentioned above, specifically,

All of these groups and organizations exist for the stated purpose of world government, with the UN in particular being a vital piece of the infrastructure used to facilitate it.


Indeed, much evidence has shown definite links between these organizations and the creation of the United Nations.[10]

But eliciting perhaps even more concern, especially since the Rockefeller family has as much control as it does, is their obsession with eugenics. It seems that the Rockefeller family has been involved in the eugenics movement since the inception of its more modern form. To be clear, eugenics is the pseudo-scientific theory that some humans are hereditarily more fit than others and that those deemed unfit should be eradicated through various means.


Its contemporary form originated with Charles Darwin’s theory of evolution and natural selection, but gained more steam when Sir Francis Galton (a cousin of Darwin’s) began to push these theories with increased vigor.


Galton also claimed that if fit or talented human beings would only marry other fit or talented human beings then the end result would be much more fit and talented offspring.


At the same time Darwin and Galton’s theories were being considered, the idea of heredity was being given more attention as well. Yet, in just a few years, what were mainly just bizarre theories came to be not only accepted but turned into a mass movement of eugenics that resulted in forced sterilizations, abortions, euthanasia and even infanticide in the United States.


This was years before these practices were introduced and intensified in Germany. In fact, it was the United States that Hitler took as a model for his own plan to eliminate “unfits.”


These practices blossomed in the years before World War II due to large scale acceptance of eugenics in academia and the media as well as massive funding from hereditary elite families such as the Rockefellers and Carnegies.[11]

Though certainly not the only proponents of eugenics, these families played an immensely important role in its expansion. The Rockefeller Foundation alone funded the American Eugenics Society to the point where its own eugenics foundation, the Rockefeller Population Council, was virtually indistinguishable from it.


The Foundation funded the Eugenics Society, which eventually changed its name to the Society for the Study of Social Biology, the name that it currently holds. Rockefeller also helped to create and subsequently fund the Kaiser Wilhelm Institute for Psychiatry and the Kaiser Wilhelm Institute for Anthropology, Eugenics, and Human Heredity.[12]

The latter was directly responsible for the coordination, funding, and implementation of the program in which Josef Mengele worked prior to his infamous experiments at Auschwitz.[13]


Indeed, many of the experiments themselves were funded by the Rockefeller Foundation via the Kaiser Wilhelm Institute for Anthropology, Eugenics, and Human Heredity.[14]


Through the Bureau of Social Hygiene, another Rockefeller eugenics foundation, John D. Rockefeller also anonymously funded the notorious racist, eugenicist, and abortion pioneer Margaret Sanger’s American Birth Control League, Birth Control Clinical Research Bureau, and Planned Parenthood of America.[15]

Sanger was the initiator of The Negro Project, a concerted effort to eliminate the black race.


In a 1939 letter to Clarence Gamble she wrote,

“We do not want word to go out that we want to exterminate the Negro population and the minister is the man who can straighten out that idea if it ever occurs to their more rebellious members.” [16]

In 1939, Sanger renamed her Clinical Research Bureau to the Birth Control Clinical Research Bureau, both integral institutions to the Negro Project, which became the Planned Parenthood Federation of America in 1942, its current name as it exists today.[17]

Considering the many connections of the Rockefellers to the United Nations and their role in its creation, it would seem logical that the two would share ideals. Indeed, population control and reduction is one of the main concerns of the UN as they fund and operate a variety of different organizations under the UN umbrella to serve just that purpose; most notably the United Nations Population Fund.[18]


Sven Burmester, a representative of the latter organization, even stated publicly his support for the barbaric practices of China’s population control programs. He said,

“China has had the most successful family planning policy in the history of mankind in terms of quantity and with that, China has done mankind a favor.” [19]

This is only one example of the ideology that is pervasive among those intricately involved in the United Nations and, unfortunately, much of the scientific community.


Although little more will be said about the elite and UN ideologies here, the evidence is readily available and it should be researched in order to gain a clearer picture of the direction this system of global governance is moving. When one has a basic understanding of the connections between the Rockefellers and the UN, as well as the common belief system of eugenics and population reduction, it is not such a stretch to see traces of these elitists in the architecture of Codex Alimentarius.


Codex, after all, is an organization created under the FAO and WHO, which are both under the jurisdiction of the UN. The connections between the Rockefellers and the pharmaceutical industry and medical establishments also serve as a motive for the destruction of the natural healthcare industry and natural supplement access.[20]

However, this evidence is not presented in order to pin the goal of global tyranny and mass population reduction on the backs of the Rockefeller family alone.


The Rockefellers are not the only elite hereditary ruling class family with this ideology, nor are they necessarily at the top of the heap when it comes to the pecking order of those that are. The Rockefellers themselves are only agents of individuals in even higher places, but who manage to remain unseen.


Nevertheless, the Rockefeller connection to Codex should not be ignored because in this case, as in many others, history predicts the future.


The globalists plans of a one-world state built upon eugenics were not born with Adolph Hitler and they certainly did not die with him. It is as alive today as it ever was.




[1] Griffin, G. Edward. “World Without Cancer.” 2nd edition. American Media. 1997. P. 235-236.
See Also, Nield, Michael. “The Police State Road Map.” March 2005, specifically, Chapter 2, “The Great Trust.”

[2] Griffin, G. Edward. “World Without Cancer.” 2nd edition. American Media. 1997. P. 235-236. See Also, Chaitkin, Anton. “Population Control, Nazis, and the U.N.!” 2002

[3] Griffin, G. Edward. “World Without Cancer.” 2nd edition. American Media. 1997. P. 235-236.

[4] Chaitkin, Anton. “Population Control, Nazis, and the U.N.!” 2002

[5] National Park Service: Biographical Vignettes - John D. Rockefeller.

[6] Council on Foreign Relations.

[7] The Trilateral Commission: Membership.

[8] National Park Service: Biographical Vignettes - John D. Rockefeller.

[9] Marrs, Jim. “Rule By Secrecy.” Harper. 2000. Pp. 20-58.

[10] Ibid.

[11] Black, Edwin. “The Horrifying American Roots of Nazi Eugenics.” History News Network, George Mason University. November 11, 2003.

[12] Chaitkin, Anton. “Population Control, Nazis, and the U.N.!” 2002

[13] Black, Edwin. “The Horrifying American Roots of Nazi Eugenics.” History News Network, George Mason University. November 11, 2003.

[14] Chaitkin, Anton. “Population Control, Nazis, and the U.N.!” 2002

[15] Takeuchi, Aiko. “The Transnational Politics of Public Health and Population Control: The Rockefeller Foundation’s Role in Japan, 1920’s - 1950’s.” Rockefeller Archives. 2009.

[16] “Birth Control or Race Control?” Margaret Sanger Papers Project #28, Fall 2001. New York University.

[17] “Birth Control Organizations - American Birth Control League - About Margaret Sanger.” New York University.

[18] United Nations Population Fund website. Accessed April 29, 2010.

[19] Watson, Steve; Watson, Paul Joseph; Jones, Alex. “Professor’s ‘Kill 90% of Population’ Comments Echo UN, Elite NGO Policies.” April 4, 2006.

[20] “Medisin.” Whitaker, Scott; Fleming, Jose. Divine Protection Publications. 2007. Pp. 12-14.

See Also: Rockwell, Llewellyn Jr. “Medical Control, Medical Corruption.”



Part 3

Structure of Health Tyranny - Codex Alimentarius

December 2, 2010



The history of Codex is important, but one should also understand the structure of Codex Alimentarius in order to understand how it arrives at its decisions.

The Codex Alimentarius Commission (CAC) is the active and controlling arm of Codex. It is the main body that makes recommendations and proposals and is consulted by the FAO and the WHO regarding food safety standards and their implementation.


Each year the CAC meets in Rome (at FAO headquarters) and Geneva (WHO headquarters) alternately with delegations from its 182 member countries. The chief delegate to the commission must be a government official or an employee of that country, and it is this individual that decides who will speak for the delegation.


No votes are taken at these meetings, as “consensus,” not voting, is the method of decision making.[1]

While the idea of “consensus” may seem reassuring, it is important to note that the Chairman of the Codex committee can prevent a delegate from even being heard at the meeting. If he is unhappy with the opposition he can simply declare that there is none and then that a “consensus” has been reached. This has occurred on numerous occasions, at least in the Codex Committee on Nutrition and Foods for Special Dietary Uses.


In some cases this has even taken the form of the Chairman cutting off the microphone of dissenting delegates. An example of this is provided by Ingrid Frazon, the head of the National Health Federation Delegation to the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU).


Frazon states:

One of the more interesting discussions that took place during the committee meetings had to do with fatty acids in infant formula for special needs. The Japanese delegate questioned why the proposed level of arachidonic acid in infant formula were set to be no less than the levels of DHA.


He pointed out that there is exceedingly little arachidonic acid in the breast milk of Japanese mothers and opposed the addition of arachidonic acid in the formula as the proposed formula would force Japanese children to consume levels of arachidonic acid that are foreign to their race and culture.


The U.S. delegation claimed that American research shows that the levels of DHA and AA should be the same. One can also wonder if the high levels of arachidonic acid in the breast milk of mothers from industrialized countries could be as a result of their diet.


After considerable discussion, the CCNFSDU Chairman Dr. Grossklaus finally came to the conclusion that the committee had reached a consensus and decided in favor of DHA and AA remaining at the same level.


Although the microphone was turned off, the whole assembly could hear the voice of the Japanese delegate shouting 'No, no, no, no!' [2]

It is obvious from experiences such as the one recounted above that any opposition to the pre-ordained agenda, in the rare instances that any exists, is promptly dealt with.


Clearly, Codex is no democracy.


The Codex Alimentarius Commission maintains 10 general subject committees[3] that often form their own sub-committees and task forces to tackle specific issues.[4]


Codex is also made up of various commodity committees, task forces, and regional coordinating committees.[5] Each of these committees deals with their own detailed product(s) and, in the end, they encompass just about everything that can be physically consumed by human beings. That is, except pharmaceuticals, which Codex does not regulate at all.


Each works under the direction of the Codex Alimentarius Commission to which they report and who ultimately approves the work of the committees. Likewise, they all work under the method of “consensus” with no votes taken to determine the final policy.

Codex uses an eight-step procedure to arrive at the final Guidelines for whatever substance it is investigating. Once the eighth step is reached, the Guidelines are either approved by the Codex Alimentarius Commission or sent back to the Committee for more changes.


Generally speaking, all of the dirty work and manipulation of language to suit the eugenics and corporate goals are done in the committees and their sub-committees. By the time the guidelines reach the Commission, the damage has been done and the text merely awaits the approval of the higher-ups.


Nevertheless, the eight-step procedure is described as follows by the FAO/WHO Codex Training Package:

  • Step 1 - The Commission decides to elaborate a standard and assigns the work to a committee. A decision to elaborate a standard may also be taken by a committee.

  • Step 2 - The Secretariat arranges the preparation of a proposed draft standard.

  • Step 3 - The proposed draft standard is sent to governments and international organizations for comment.

  • Step 4 - The Secretariat forwards comments to the Committee.

  • Step 5 - The proposed draft standard is sent to the Commission through the Secretariat for adoption as a draft standard.

  • Step 6 - The draft standard is sent to governments and international organizations for comment.

  • Step 7 - The Secretariat forwards comments to the committee.

  • Step 8 - The draft standard is submitted to the Commission through the Secretariat for adoption as a Codex Standard.[6]

Essentially, the Commission introduces a standard to be debated, at which point the designated committee takes up the standard and creates a draft of the guidelines.


This draft is circulated to member countries who comment on it. These comments are reviewed and potentially incorporated into the next draft which is then adopted by the committee. This draft is then redistributed to member countries for comment. The committee then adopts the guidelines and sends them to the Commission for final approval.


Both the Commission and the committee can require that the draft guideline be pushed back to a previous step if it so desires.[7]

While one might at first be tempted to accuse Codex of being bogged down in bureaucracy, this setup is only for show. Like most of the international organizations that set global agendas, bureaucracy exists only to confuse the lower level participants that engage in virtually meaningless debates during the meetings. When an agenda is meant to be pushed through, bureaucracy doesn't hinder it at all. As mentioned earlier, all that is needed is the illusion of consensus and one is declared, even if the illusion itself is weak.

Codex Alimenarius is a true health tyranny: from its ideological foundations, to its connections with key players within dictatorial regimes and eugenics movements, to its hierarchical structure which restricts openness and debate.


Only by exposing this committee and its stated goals can we hope to restore our health freedom.



[1] “What is Codex?” American Holistic Health Association,
[2] Franzon, Ingrid. “Report from the Thai Codex Meeting.” Codex Alimentarius: Global Food Imperialism. Ed. Scott C. Tips. FHR 2007. Pp. 199.
[3] Codex Alimentarius: Committees and Task Forces - General Subject Committees. USDA Food Safety and Inspection Service. 
[4] MacKenzie, Anne A. “The Process of Developing Labeling Standards for GM Foods In The Codex Alimentarius.” AgBioForum - Vol.3 Number 4, 2000. Pp. 203-208
[5] Codex Alimentarius - USDA Food Safety and Inspection Service.

[6] “FAO/WHO Training Package - Section Two: Understanding the Organization of Codex” CodexEurope.
[7] “Codex Alimentarius: Global Food Imperialism.” Ed. Scott C. Tips. FHR. 2007.


Part 4

The Language of Health Tyranny

Decoding the Codex Alimentarius Guidelines For Vitamins and Supplements

December 17, 2010




Perhaps the most publicized aspect of Codex Alimentarius is the threat it poses to free access to vitamin and mineral supplements.


While there are varying opinions on the effects the Codex guidelines would have on dietary supplements, there is little debate about the fact that these effects would be detrimental. At best, the guidelines will reduce dose levels to minuscule amounts too small to be beneficial, as well as causing the prices to skyrocket for both consumers and producers.[1]

However, a more frightening scenario is possible and, unfortunately, quite likely. When one examines the evidence, it is clear that the effects of the Codex guidelines will do more than just reduce the level of nutrients available in supplements. The truth is that it will actually go so far as to list vitamins, minerals, herbs, and other nutrients as toxins, while at the same time listing dangerous chemicals as nutrients.

The committee charged with completing this task is the Codex Committee on Nutrition and Foods for Special Dietary Uses (CCNFSDU), chaired by Dr. Rolf Grossklaus, until recently.


In 2005, and in the face of much opposition from the informed pro-supplement and natural health community, the CCNFSDU approved The Guidelines for Vitamin and Mineral Food Supplements, the set of rules by which vitamin and mineral supplements may very well be removed from the market.[2]

The Natural Health Federation (NHF) and the Alliance for Natural Health (ANH) have traditionally been the most vocal opponents of Codex’s attempts.


However, it appears that these organizations, as well as the many others that oppose Codex such as the Natural Solutions Foundation (NSF), are fighting a losing battle. While these groups and individuals spend countless amounts of money and energy fighting this global tyranny, their efforts amount to little more than rearranging the deck chairs on the titanic.


At this point, their work focuses on lessening the blow from the Codex guidelines. Unfortunately, it does nothing to stop the blow from coming, nor does it protect against subsequent heavier blows. While these statements are not meant to belittle their work, it is meant to show that the battle is not within Codex itself, but outside of it.

That said, the idea that nutrients (vitamins and minerals) will be considered as toxins is not readily apparent even when reading the actual guidelines for Vitamin and Mineral Food Supplements. Nowhere in the guidelines is it stated that “nutrients will be listed as toxins.” However, as with most governmental and institutional mandates, it is hidden within coded language and meticulous directives.


Such a technicality exists in this instance in the form of risk assessment; the technique specified by Codex to evaluate the safety of vitamin and mineral supplements. In section 3.2.2 (a), the Guidelines state:

Upper safe levels of vitamins and minerals [should be] established by scientific risk assessment based on generally accepted scientific data, taking into consideration, as appropriate, the varying degrees of sensitivity of different consumer groups. [3]

Risk assessment, while seemingly benign, is actually crucial to the ability of Codex to justify the ban of vitamin and mineral supplements.


This concept works on the assumption that the item being tested is inherently dangerous and toxic. This method is completely the opposite of what should be used when evaluating vitamins and minerals.


As Dr. Rima Laibow states in her article "'Nutraceuticide' and Codex Alimentarius:"

This use of risk assessment, of course, represents a major deflection from the real use and value of risk assessment, which is to make sure that people are not exposed to the dangerous industrial chemicals that have serious and sometimes lethal effects on them and their children.[4]

By applying “scientific risk assessment” to nutrients and supplements, they are essentially considering them toxins as they are lumped into the same category as chemicals and poisons.


There is no need to explicitly state that “nutrients are toxins.” This is done by default. So, in the end, we have the categorization of vitamins and minerals that are essential to human health and life as something that is actually toxic. In this sense, we are entering the world of doublethink.

Regardless, this is the position of Codex, as well as the position of the U.S. Delegation throughout the discussion.[5]


Indeed, even many alleged “health freedom” International Non-Governmental Organizations were either gullible enough to be taken in by the promise of the benefits of risk assessment, or morally bankrupt enough to be bought off by the pharmaceutical industry or others who might benefit from the demise of the natural supplement industry.


Yet, some of the support for risk assessment methods early on seems to have been based on the fear of the implementation of maximum limits proposed by European countries like France. These limits would have reduced the potency level of each pill to no more than 15% Recommended Daily Intake (RDI), a figure that is already set much too low. [6]


Yet those who favored risk assessment seemed to jump from the frying pan into the fire. As Scott Tips of the Natural Health Federation writes:

The so-called 'science-based risk assessment' for establishing Safe Upper Limits (maximum levels) for vitamin-and-mineral potencies, to which the EU has agreed, and about which the Americans are as happy as flies on cow dung, is nothing but a trap. The Americans think that they will be able to get real science to establish high maximum levels for their vitamins and minerals and then sell them to European consumers by the bushels.


But by the time the Europeans get through applying their science, those maximum limits will be so low toddlers would be lucky to get any nutritional value out of Codex-harmonized vitamins and minerals. The European Union’s Scientific Committee on Food has already started using its science-based risk assessment to establish laughably low maximum limits for European vitamins.


And, lately, I have begun to see a growing concern, if not outright fear, in the faces of some science-based risk-assessment proponents that perhaps things might not go their way here after all.[7]

Indeed, things are not going “their” way. That is, if the general wish is that Codex would offer up new trade opportunities for American supplement manufacturers in the form of a new European market.


To be sure, it takes monumental ignorance to actually believe this. Nevertheless, trade associations like the International Alliance of Dietary Food Supplements, National Nutritional Foods Association, and even the Council for Responsible Nutrition are proclaiming that Codex poses no threat to their access to supplements and, specifically, to the DSHEA law which was passed in 1994.

In general, those individuals who rely on these organizations for their knowledge of the legal and political workings of the industry take these reports as truth, trusting them as “credible” sources. It should also be noted that it is widely known that members of various natural health/supplement trade organizations are increasingly being purchased by the pharmaceutical industry themselves.


Once this is acknowledged, one can understand more fully how disinformation spreads around the supplement community and encourages apathy and a false sense of security among the populace.[8]

Maximum Upper Limits on vitamins will be set for the few temporarily remaining nutrients as well as the complete removal of others from multi-vitamin supplements. The ramifications for human health and national sovereignty will therefore be extremely destructive.


As always, this global domination and subversion of national sovereignty will be done in the name of trade, and the true aims of the perpetrators will be cloaked in flowery language, wordplay, and semantics. It will also be done right under our noses.




[1] “Codex Alimentarius: Codex - government and corporate control of our food supply.” Alliance for Natural Health Europe.
[2] “Guidelines for Vitamin and Mineral Food Supplements.”
[3] Ibid.
[4] Laibow, Rima. “’Nutraceuticide’ and Codex Alimentarius.” Alternative and Complementary Therapies, October 2005. P. 227.
[5] Tips, Scott C. “Breathe Easier - Codex Adjourns.” Codex Alimentarius: Global Food Imperialism. Ed. Scott C. Tips. FHR. 2007. P. 33.
[6] Ibid.
[7] Tips, Scott C. “A Meeting Of Two.” Codex Alimentarius: Global Food Imperialsim. Ed. Scott C. Tips. FHR. 2007. P. 101.
[8] Tips, Scott C. “The Maginot Mentality.” Codex Alimentarius: Global Food Imperialism. Ed. Scott C. Tips. FHR. 2007. P 220.




Part 5

S. 510 and Codex Alimentarius Link

Tracking, Tracing, and Monitoring Independent Food Production
December 4, 2010


Regulated out of existence under S. 510

Being honest, I must confess some slight personal agitation at the thought of writing another article on yet another “food safety” bill making its way through congress with the words “tyranny” and “Codex” written all over it. It seems that every legislative session, we are faced with the prospect of the same food bill cloaked in a different name.


Invariably, this bill seeks to corral all food production into the hands of a few major corporations and essentially destroy the ability of the population to feed themselves.


Here in late 2010, we have the new version of food imperialism known as S.510, the Food Safety Modernization Act.

While it is true that S.510 contains new and improved tyrannical sections that are unique specifically to it, the truth is that it is merely a repackaging of past bills (See here and here ) and attempts to control people through food. It is also yet another attempt to implement Codex Alimentarius guidelines under the guise of domestic legislation.

One example of hidden Codex guidelines in the Food Safety Modernization Act are the overly broad provisions regarding “traceability.”


The desire for enhanced traceability of food products is sold to the public as a desire to better respond to food-borne illnesses and follow them back to their source. However, as with almost anything that comes out of the mouth of government, there is a more sinister role that traceability programs have to play.

Essentially, traceability has little to do with food safety in this context. While no one could argue being able to trace food contamination back to the source is a bad thing, the fact is that these mechanisms already exist.


Unfortunately, they are generally ignored and unused when it comes to adverse health effects related to food produced by multinational food corporations. While there is always an exception to the rule, it is a fact that international corporations are by far the source of food adulteration more often than small independent farms.

The real reason behind traceability programs lies in the desire to monitor where food is coming from to ensure that, in the future, it only comes from large agribusiness. Hence, the new traceability procedures involve massive financial, management, and bureaucratic burdens placed on the shoulders of mainly small “food producers.”

It should be pointed out that, while it is true that major corporations will also be burdened with these regulations (unless the Secretary exempts them), it is also true that a company that makes billions in profits can afford to deal with them. Your neighborhood farm down the road simply can’t.

For all the claims that small independent producers will be exempted, the fact is that the “exemption” is merely semantics. Small independent producers will be held to essentially the same guidelines as Big Agro. This is because, in order to be exempted from the regulations as S.510, they have to submit to similar regulations as the S.510 regulations themselves dictate.


As Eric Blair points out in his article Why the Tester Amendment Does NOT Help Small Food Producers Under S.510:

Those [S.510 Tester Amendment Exemption Requirements] bear a striking resemblance to the ‘expensive’ food safety plans outlined in subsection (h) of S.510 that small producers are supposedly exempt from. In other words, they must submit similarly comprehensive plans just to qualify to be exempt from creating them.


But it gets worse.


If Grandma wants to sell her famous raspberry jam at the county fair (within 275 miles of her canning kitchen) she will indeed be a small producer exemptions, but not before she forks over 3 years of financials, documentation of hazard control plans, and local licenses, permits, and inspection reports.


She must submit this documentation to the satisfactory approval of the Secretary; and if she fails to do so, the entirety of S.510 can be enforced on her.

That’s hardly what I call an exemption.

He goes on to point out that the bill does not explicitly make it illegal to sell food independently produced, but it does make it so cumbersome that small producers will be unable to maintain compliance with the law.

While one could successfully argue that by forcing independent producers to file information and obtain permits and licenses is in fact making the production of food illegal, there is no doubt that small producers will be forced out of business by the overbearing regulation.

Nevertheless, cumbersome traceability provisions have surfaced before in other areas. In reading the traceability-related sections of S.510, there is a striking similarity between the language of the bill and that of Codex Alimentarius in its own proposed guidelines.

The HACCP (Hazard Analysis Critical Control Point), a “food safety” methodology used by Codex Alimentarius (and addressed in S.510), plays an important role in the tracking, tracing, and monitoring of food production.


Under this system, food business operators (defined so broadly so as to include both big agribusiness and recreational gardeners) are required to,

“identify any steps in their operations which are critical to the safety of the food; implement effective control procedures at those steps; monitor control procedures to ensure their continuing effectiveness; review control procedures periodically and whenever the operations change.”

Likewise, in the document entitled, “Recommended International Code of Practice General Principles of Food Hygiene,” Codex states that,

“Where necessary, appropriate records of processing, production and distribution should be kept and retained for a period that exceeds the shelf-life of the product. Documentation can enhance the credibility and effectiveness of the food safety control mechanism.”

Although the language of the bill and the Codex document are not identical in every section, they are similar.


Unfortunately, this is all that is needed to initiate the implementation of Codex Alimentarius guidelines in the United States.

However, there is yet another danger posed by S.510 in regards to Codex Alimentarius. The fact that this bill provides the FDA, HHS, and even DHS with even more authority over food production, transportation, and consumption should be alarming enough.


But because these agencies often respond to policy as much as they do law, the chances of Codex Alimentarius guidelines being implemented domestically rises sharply. This is due to the fact that no congressional approval would be needed to implement them. Simply an executive order or change in policy from the executive branch or even the FDA, HHS, or DHS acting independently would be enough to enact Codex guidelines in the United States.

Because Codex Alimentarius guidelines are enforced by the WTO, any dispute brought before the WTO and its dispute settlement board could essentially force the United States to buckle under and implement Codex guidelines. With the passage of S.510, the need to gain congressional approval for such a change would be effectively erased.

Yet while Codex guidelines can be enforced through the WTO in one fell swoop, it is much more likely that they will be implemented by stealth. Introduced gradually and under the cover of domestic legislation, the chance of organized public resistance is greatly reduced.


Without a doubt, the majority of Americans have no idea what Codex Alimentarius actually is. In fact, it is an unfortunate reality that the majority of the American public have no idea what S.510 is. Even to the relatively informed individual, the legislation is merely just another government power grab.


Little do they know that is a major step forward on the path to a global dictatorship which uses food as a weapon and a means of control.



Those who ridicule activists and opponents of S.510 as paranoid conspiracy theorists march unwittingly down a road which leads directly to just such a global tyranny where food will be most definitely taken - but not for granted.



Part 6

The Methods of Health Tyranny

Codex Alimentarius "Risk Assessment" of Vitamins And Nutritional Supplements
December 24, 2010




In the previous article I addressed the issue of the language of “risk assessment” techniques used to determine the dangers of consuming vitamin and mineral supplements as well as how this methodology would be used to classify nutrients as toxins.


For the most part, I focused on the fact that “risk assessment” is clearly an inappropriate testing method to apply toward vitamins and minerals. This is because “risk assessment” is designed to be applied to substances that are known to be toxic for the purpose of establishing an upper safe levels of toxicity to them.

But there are other problems with the process of risk assessment as well. First, the current methodologies are based upon the assessment of entire groups of nutrients as opposed to the individual nutrients that make up the group. This method is called the nutrient group approach, a method which depends upon the lumping of many different forms of a nutrient into one category rather than testing each individual form separately as is done for toxic chemicals.[1]

An example would be assessing Vitamin B as a whole group.


Assessing Vitamin B3, Vitamin B12, and Vitamin B6 as separate and individual nutrients is called the nutrient form approach and would be the more rational method to apply (even though risk assessment should not be used in the first place) because the alleged risks posed by these supplements are themselves dependent upon the form in which it occurs.

For instance, Vitamin C, in the form of ascorbic acid, has been known to cause loose bowels in some people who take it in very high doses. Yet, when taken as calcium ascorbate, this does not occur. Indeed, this is about the most severe side effect from a vitamin supplement that one can document.


Yet under the risk assessment process using the method of the nutrient group approach, Vitamin C as a whole would be regulated based upon the “risks” associated with the ascorbic acid form of Vitamin C. Therefore, the ascorbic acid form of vitamin C would be the basis for the setting of the upper safe levels or the Maximum Upper Limits of Vitamin C.


This is because this particular method takes the most “toxic” form of the tested substance and uses it for the basis of its regulation.[2]


In this case, the nutrient group is considered only as safe as its most dangerous form.

Indeed, this is the method advocated by the FAO and WHO. In a joint FAO/WHO report published in 2005 entitled “A Model for Establishing Upper Levels of Intake for Nutrients and Related Substances,” reports of conclusions dealing with Vitamin C, Iron, and Zinc are all listed as the nutrient group and not the various forms in which they occur.[3]

Clearly, there is a double standard within the FAO, WHO, and Codex regarding the safety testing of vitamin/mineral supplements and that of chemicals. As Paul Anthony Taylor points out, in the process used for risk assessment of toxins, pesticides, etc., each individual substance is analyzed as a “separate chemical entity.” [4]


This is a recurring theme in the discussion of Codex and its guidelines for various forms of food substances and supplements and can be easily seen in its regulation requirements for GMO’s as well. While GMO products are allowed in the international food chain, nutrients are treated as dangerous substances. In this case, simply giving nutrients the same treatment as toxic chemicals would be an improvement over their current treatment.

A second problem with the risk assessment methodology is the fact that it completely ignores the positive health benefits of nutritional supplements and focuses only on their risks.


This is especially important because when a regulatory agency determines, as Codex and other agencies apparently have, that any risk, no matter how insignificant it is, may constitute an “unreasonable risk of illness or injury” it may therefore be banned. Unfortunately, this is actually provided for under the DSHEA law passed in the United States in 1994.


This, however, is essentially what the risk assessment procedure is all about - assessing dangers not benefits.

Not surprisingly, most of the evidence such as observational and clinical data that demonstrates a positive effect is ignored. Instead, all we are left with is “peer-reviewed” studies of isolated nutrient forms that are so varied in terms of experimental design, dosages, and even the nutrient forms themselves that they are virtually non-comparable.


Not only that, but the form of the vitamin being tested is often in a synthetic form as opposed to its natural state with very little concern given to the individuals’ nutritional requirements or current state of health. Even follow up times vary significantly. [5]


Paul Anthony Taylor explains this in his article “Nutrient Risk Assessment: What You’re Not Being Told,” when he writes:

In some areas of the world, such as the United States and the United Kingdom, supplemental nutrients have been in use for over half a century now.


As a result, some doctors and practitioners have built up extensive databases containing carefully documented case histories of patients who have used high doses of vitamin and mineral supplements, safely and effectively, for many years. Similarly, research scientists have conducted numerous small-scale clinical trials that have produced impressive results providing clear evidence of the safety of high dose supplements in human beings.

Nevertheless, a serious flaw in the current regulatory approach to nutrient risk assessment is that some of the most valuable potential sources of positive scientific evidence regarding the use and safety of supplements, such as the types of observational and clinical data described above, are generally ignored.


Instead, the sole source of evidence that is considered are peer-reviewed scientific studies of particular nutrient forms, which are often non-comparable owing to differing experimental designs, nutrient forms delivered, dosages given, and so on.

The net result of this is that the evidence-base for nutrient risk assessment tends to be skewed towards consideration of negative outcome studies that used a single vitamin or mineral - frequently in a synthetic rather than a naturally-occurring form - without full and proper consideration of the participants’ overall state of health or individual nutritional requirements.


Moreover such studies are often non-comparable owing to differences in their follow-up periods; the fact that many have been conducted on diseased rather than healthy populations; and that many were started well after disease states had already been initiated.


As a result, a process that may appear rational, objective and scientific to the lay person or even the regulator, is, we discover, actually flawed and deeply unscientific. [6]

Yet the problems extend to more than just unscientific expansion upon unreliable models.


There is both rhyme and reason to the madness of Codex Alimentarius. It is on the basis of the aforementioned science that Codex works to regulate nutrients as if they are industrial chemicals. This goal is achieved through the use of risk assessment methodology by setting Maximum Upper Limits (also described as Maximum Upper Levels or Upper Safe Levels), and later Maximum Permitted Levels of nutrients.


There is a fine line between the two but the difference is a very important one.





[1] Taylor, Paul Anthony. “Nutrient Risk Assessment: What You’re Not Being Told.” P.2
[2] Ibid.
[3] A Model for Establishing Upper Levels of Intake for Nutrients and Related Substances, WHO/FAO. 
[4] Taylor, Paul Anthony. “Nutrient Risk Assessment: What You’re Not Being Told.”  P.2 Ibid.
[5] Ibid.
[6] Ibid.




Part 7
Codex Alimentarius - The Global Fallout of Health Tyranny

January 26, 2011



In past articles, I have written extensively on the dangers of using Risk Assessment when dealing with vitamins and minerals.


I have explained how the risk assessment methodology is being used to establish both Upper Safe Levels and Maximum Permitted Levels, as well as demonstrated the connections between Codex Alimentarius and the German Federal Institute for Risk Assessment (BfR).


These connections are important because it is BfR that has been contracted by Codex to provide scientific information and advice on nutritional supplements using just this process. In this and subsequent articles, I will examine in more depth the findings presented by BfR and the ramifications they will have for access to vitamin and mineral supplements the world over.

In 2005, BfR published “Use of Vitamins in Foods: Toxicological and nutritional-physiological aspects,” its list of recommendations for the maximum levels of nutrients in vitamin and mineral supplements. Of the many tables included in these results, Tables 3 and 4 are of particular interest.


Table 3 is an overview of the BfR teams’ classification of vitamins and minerals into supply and risk categories (each of these categories being separate).

Supply categories deal mainly with the status of the supply of tested materials such as their possible contamination or their potential to be contaminated during shipping as well as the intake status.


However, the risk categories have to do with the potential for nutrients and vitamins to cause adverse effects.

The risk category is divided into High risk, Moderate risk, and Low risk, and is based on “how large the margin is between recommended/observed intakes and the defined UL” [Upper Limit]. [1] Rather, how much further than the Recommended Daily Allowance (RDA) a nutrient must go to reach the level of perceived adverse side effects (the Upper Limit).[2]


Indeed, Table 2, which is a different chart showing the criteria for each risk category, is entitled “Various degrees of probability that a nutrient leads to adverse side effects.” [3]


This in itself should trigger questions as to what amount of “proof” this study actually offers.

The idea that it is the probability, not a clearly defined set of risks or causes of those risks, shows that the study has not actually proven that nutrients pose a threat of adverse side effects, even when using the risk assessment process to begin with.

Yet BfR and subsequently Codex Alimentarius continue to use this data to create a maximum permitted level for nutrients. Vitamins A and D, Beta-Carotene, Niacin (as Nicotinic acid), Sodium, Potassium, Calcium, Iron, Iodine, Zinc, Copper, and Manganese are all added into the High risk category, while the best that any other nutrient or mineral can hope for is the Low risk category. None fall into a no-risk category, because no such category exists in this type of study.

Clearly, as one can see from the BfR results, the levels suggested by Codex for the Maximum Permitted Levels are excessively low. For instance, the most liberal dosage allowed is for Vitamin C at the levels of 225 mg. Yet the Upper Safe Levels of Vitamin C are nowhere near this small amount.

Even according to Medline Plus, administered by the National Institute of Health and the U.S. National Library of Medicine, the Upper Safe Levels for Vitamin C is 2,000 mg for adults above the age of 18.[4]


This is a difference of 1,750 mg set by an agency that is not considered exactly friendly towards nutritional supplements or natural healthcare. Of course, for individuals with some kind of sickness such as cancer, the limits on Vitamin C intake are much higher.[5]

The limits placed on Vitamin D are perhaps the most egregious. BfR sets the Maximum Permitted Levels of Vitamin D at 5 mcg while even the Medline service lists the Upper Safe Limits at approximately 50 mcg (2000 IU).[6]


A comparison of the Upper Safe Limits set by the Medline Plus system (under the direction of the aforementioned government agencies) can be viewed by going on to the Medline website and the BfR site.

Keep in mind, as mentioned earlier, that the U.S. agencies who established these Upper Safe Limits are not exactly those that can be considered champions of health freedom, natural healthcare, or nutritional supplementation. Using their figures, however, provide an opportunity to see just how dramatic a decrease in the level of nutrition is caused by BfR’s Maximum Permitted Levels.

While some of these differences are smaller in scale than others, most BfR MPLs are much more than double their Medline counterparts. The standards for copper are quite telling as there is a 10,000 mcg difference between the two.

The problem, however, goes even deeper than the establishment of MPLs and USLs. The Recommended Daily Allowances (RDAs) are of great concern as well. This is not only because they are often instrumental in the setting and justification of MPLs and USLs, but also because they are referenced for human health and individual intake.

In the United States, the RDA is often taken in conjunction with the Estimated Average Requirement (EAR) under the umbrella of the Dietary Reference Intake (DRI) which is set by the Institute of Medicine of the National Academy of Sciences.[7]


The RDA is officially defined as,

“the average dietary intake level that is sufficient to meet the nutrient requirement of nearly all (97 to 98 percent) healthy individuals.” [8]

The EAR is defined as,

“the daily intake value that is estimated to meet the requirement... in half of the healthy individuals in a... group.” [9]

It goes on to say,

“At this level of intake, the other half of a specified group would not have its nutritional needs met.” [10]

While this article will not deal in depth with this subject, it should be noted that the Institute of Medicine of the National Academy of Sciences has recommended that the national standard of nutritional intake be shifted from the RDA to the EAR.[11]


This would effectively slash the DRI by close to half due to the fact that the original referenced values of nutritional intake would be affected likewise.

Another main concern related to RDAs is the fact that they are not adequately set to promote optimal human health. Indeed, RDAs are set at the lowest level for prevention of single-nutrient deficiency diseases. This means that the RDA is not the level at which intake of a particular nutrient is sufficient for good health, but the lowest level that must be maintained in order to prevent a particular deficiency disease.

In the case of Vitamin C, for instance, the diseases would be scurvy or rickets. Put plainly, RDAs are the levels of nutritional intake needed to barely get by, not remain healthy.[12]


As James South points out in his article, “Vitamin Safety, RDAs and the Assault on Vitamin Freedom,” the Recommended Dietary Allowances from 1980 plainly stated as much.


South quotes them as saying:

The requirement for a nutrient is the minimum intake that will maintain normal function and health... For certain nutrients, the requirements may be assessed as the amount that will just prevent failure of a specific function or the development of specific deficiency signs - an amount that may differ greatly from that required to maintain maximum (i.e. optimum) body stores.[13]

This is a source of confusion for many consumers who believe that RDAs are the levels at which their intake is topped out and adequately achieved.


Add to this the fact that RDAs are continually being lowered by the agencies responsible for setting them.

In 1989, the National Academy of Sciences revised the RDAs from their already meager levels set in 1980 to even lower levels, some of them by half. Interestingly enough, the National Academy of Sciences exercised some twilight-zone logic similar to Codex Alimentarius when these decisions were made.


The assumption made by the agency was that Americans are generally healthy people and, because they generally fail to consume the 1980 RDA levels of nutrients, then a lower standard is adequate for good human health.[14]

Clearly, either lowering the RDAs or creating MPLs is a threat to the natural supplement industry from the perspective of the consumer as well as the manufacturer. Even without acknowledging the ideological and financial reasons behind the push to end access to vitamin and mineral supplementation, the setting of MPLs, especially at low levels, would create a vast increase in the cost of supplements wherever they were sold.


Consumers would then be forced to purchase many more times the amount of supplements to achieve the same result as their current dosage.

If the MPLs reduce a supplement's levels by half, as many do, then the consumer would need to take two capsules for every one he/she currently takes to achieve an equal amount of nutrition. Translate this into buying two bottles for every one bottle purchased at the current levels.


This would not only have a crippling effect on consumers, but the industry itself would face similar repercussions as the option of natural supplementation would become unaffordable. Even the supplements themselves would suffer, as each capsule/pill/dose would therefore have to be produced using more filler materials than actual nutrients.

This is actually a concern with another Codex policy that is much less well-known than that of MPLs - minimum levels of nutrients. While many may see this as contradictory to Codex’s general position toward natural supplements, it is in fact included within the Codex Guidelines.


Section 3.2.1 of the Guidelines states,

“The minimum level of each vitamin and/or mineral contained in a vitamin and mineral food supplement per daily portion of consumption as suggested by the manufacturer should be 15% of the recommended daily intake as determined by FAO/WHO.” [15]

No doubt some, out of ignorance, will assume that this position is positive.


In fact the opposite is true. The setting of minimum levels is merely part of a two-pronged attack on vitamin and mineral supplements, and levels of nutrition in general. The problem with this position is that it prevents manufacturers from adding trace amounts of vitamins and minerals to supplements that may be desired or needed to aid in the processing of the main nutrient. Instead, filler will have to be added.


As Scott Tips writes:

Besides the obvious moral problem of prohibiting people from freely and voluntarily contracting with one another as they wish, the practical problem with minimum levels is that they foreclose manufacturers from adding something useful (such as a vitamin or mineral) in a capsule or tablet instead of something worthless, like a filler or excipient. In my view, it would be better for a person to get some additional nutritive value from a capsule or tablet, than nothing at all.[16]

Keep in mind, the MPLs of vitamin and mineral supplements will be set so low, according to the risk assessment studies like those of BfR being conducted, that it will be virtually impossible to include trace amounts of supplements below the required 15% of the already low levels of the RDA.


They might as well not be included at all, which is the goal of Codex in the first place.




[1]  “Use of Vitamins in Foods: Toxicological and nutritional-physiological aspects.” Domke, A., Grosklaus R., Niemann B., Przyrembel H., Richter K., Schimdt E., WeiBenborn B., Worner B., Ziegenhagen R., Federal Institute for Risk Assessment, BfR, 2005. P.18.
[2] Ibid.
[3] Ibid.
[4] “Vitamin C.” Medline Plus website. 
[5] “Vitamin C.” Oregon State University. Linus Pauling Institute. 
[6] “Vitamin D.” Medline Plus Website. 
[7] South, James. “Vitamin Safety, RDAs and the Assault on Vitamin Freedom.” National Health Federation. March 2004.
[8] Ibid.
[9] Ibid.
[10] Ibid.
[11] Ibid.
[12] Ibid.
[13] Ibid.
[14] Ibid.
[15]“Guidelines for Vitamin and Mineral Food Supplements.”
[16] Tips, Scott C. “Codex Gets One Step Closer To Control.” Codex Alimentarius: Global Food Imperialism. Ed. Scott C. Tips. P.49-50. 2007.