EU Commission review of composition requirements for TDR is a positive step but industry warns about remaining formulation issues

Posted On: 9th November 2022

Ahead of the enforcement of the Delegated Regulation amending Delegated Regulation 2017/1798 on Total Diet Replacement (TDR) on 29 November 2022, TDMR Europe released a statement to welcome the review of essential fatty acids (EFA) and magnesium requirements but raises awareness of the need to review the protein requirements next.

TDMR Europe welcomes the review of EU composition requirements for TDR but warns about remaining formulation issues

“Following a targeted campaign that TDMR Europe has implemented over the past five years and our close coordination with Commissioners, Member States’ representatives and MEPs, the European Commission has reviewed the requirements for magnesium and essential fatty acids for the composition of TDRs. This change in the 2017 Delegated Act is crucial to make sure that the manufacturing of TDRs is based on sound science and the products remain shelf stable and palatable”.

“Yet, the industry remains concerned about the protein requirements in Delegated Regulation 2017/1798. The protein levels set out in the regulation are much higher than those in the previous legislation, are not in line with the latest scientific evidence and present important food technology problems for the industry as they impact their products’ texture and palatability”.

“TDR is a product that has been marketed and used safely in Europe for over 35 years and several scientific studies have shown its potential in tackling obesity and improving comorbidities, such as type 2 diabetes, cardiovascular disease, osteoarthritis and obstructive sleep apnoea”.

“TDMR Europe will keep working closely with policy makers to help them gain a better understanding of TDRs and will continue coordinating with stakeholders to secure fit for purpose legislation for these products”.

On 27th October, the Delegated Regulation 2017/1798 on TDRs composition and labelling requirements that was adopted in June 2017 reviewing the Directive 96/8 started to apply. Today the Delegated Regulation amending Delegated Regulation 2017/1798 was published in the Official Journal and will start to apply on 29 November 2022. With this new regulation the European Commission reviewed the composition requirements for magnesium and EFAs to bring them in line with the 2021 EFSA recommendations. This review took place following a letter from TDMR Europe to the Commission which raised awareness of the latest scientific research on alpha-linolenic acid (ALA), linoleic acid (LA) and magnesium and requested a review by EFSA of their 2015 opinion on TDRs composition.

TDRs, which include very low-calorie diets (VLCDs) and low-calorie diets (LCDs), are specifically formulated programmes that are based around formula foods that aim to replace the whole of the daily diet. You can find more information on TDRs here.

TDMR Europe is the European association for manufacturers and distributors of formula diet products, including total diet replacement (TDRs) and meal replacement (MRPs) which provide weight loss and weight management programmes for people with obesity and overweight. TDMR Europe works to secure appropriate and proportionate European legislation for slimming foods and is in close continuous dialogue with a wide variety of stakeholders such as policymakers and senior officials in the relevant bodies to do this. More information on TDMR Europe is available here.

Aris Myriskos

Press Office, TDMR Europe Secretariat