Skip to main content
Herbal & Supplement Testing (rare in Europe)

Food Safety Audit Companies: What EU Supplement Brands Should Know

Comparing food safety audit companies? See who audits what in the EU, where supplement brand responsibility sits, and how to prepare your own audit file.

Nour Abochama Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex

Kernpunt

Comparing food safety audit companies? See who audits what in the EU, where supplement brand responsibility sits, and how to prepare your own audit file.

A retail buyer asks for proof that your capsule product line has been “audited for food safety.” You open a search engine, type “food safety audit companies,” and get a long list of providers, each describing a different service. Before you compare quotes, you need to know what the audit is for, who is asking for it, and which legal obligations sit with you regardless of who performs it.

This article separates the different meanings of “food safety audit” in the EU and explains where responsibility for food supplements actually sits. It then gives you a practical list of what a credible audit of a supplement operation should cover.

Three different things people call a food safety audit

The phrase covers at least three situations, and mixing them up leads to buying the wrong service.

  1. An official audit of a national control system. The European Commission carries out controls aimed at monitoring the implementation and enforcement of EU legislation on food and feed safety [3]. It is not an audit of your company.
  2. An audit requested by a customer, retailer or distributor. Ask whoever requests it to define the scope in writing before you buy anything.
  3. Your own internal review. This is a gap check against the requirements for your product category before anyone else looks at it.

A private provider can help with the second and third. It cannot replace the responsibilities you carry as a business placing a product on the market, and it does not stand in for the official system described next.

How official EU audits work

The European Commission carries out controls and other oversight tasks to monitor how EU legislation on food and feed safety is implemented and enforced [3]. Within the Commission, the Directorate-General for Health and Food Safety holds that responsibility, and a dedicated Directorate for Health and Food Audits and Analysis dedicates most of its resources to these controls [3].

Understanding the process is useful even if you are never audited by the Commission. It shows how the EU handles audit evidence.

  • Preparation comes first. The audit team gathers information beforehand by sending out an audit plan and a pre-audit questionnaire [3].
  • Teams are small. The team is typically composed of two auditors, often with a national expert from an EU country present [3].
  • Reports are public. The Directorate produces reports of these audits, which are, with few exceptions, publicly available [3].
  • Deficiencies lead to follow-up. Audit reports may make recommendations to assist the competent authorities in taking corrective measures, and the actions taken are followed up either administratively or by on-the-spot audits [3].
  • Sector overviews exist. Overview reports summarise the situation in a certain sector across Europe and are presented to the EU Member States in the Standing Committee on Plants, Animals, Food and Feed [3].

You can borrow this structure for your own preparation: a plan, a questionnaire, a written report and a route from each finding to a corrective action.

Where responsibility sits for a food supplement

Many brand owners assume that hiring an audit firm moves the burden onto the auditor. Based on the sources below, responsibility sits with the business placing the product on the market.

According to the EU General Food Law Regulation (EC) No 178/2002, food supplements are considered as foodstuffs, and responsibility for their safety lies with the food business operator placing the product on the market [2]. The same source states that it is the responsibility of the manufacturer, importer, supplier or distributor to ensure that a food supplement placed on the market is safe [2].

For a non-EU brand, this matters. If you import into the EU, you may be one of the parties carrying that responsibility, whatever your contract manufacturer says.

The objective of the harmonised rules in Directive 2002/46/EC is to protect consumers against potential health risks from food supplements and to ensure that they are not provided with misleading information [1]. Any audit you commission should be scoped against these two aims: safety and non-misleading information.

What a credible audit of a supplement operation should cover

Use the following areas to test whether a provider understands supplements specifically, rather than food manufacturing in general.

Vitamin and mineral forms

Annex I to Directive 2002/46/EC lays down a harmonised list of vitamins and minerals that may be added for nutritional purposes, and Annex II contains a list of permitted sources from which they may be manufactured [1]. The trade of products containing vitamins and minerals not listed in Annex II has been prohibited from the 1st of August 2005 [1]. An audit should compare every vitamin and mineral source in your formulas with the current version of Annex II, including its amendments [1].

Botanicals and other substances

The use of ingredients other than vitamins and minerals, such as botanicals, may be authorised under other specific legislation depending on the nature of the substance, for example novel foods, substances for the fortification of food, or foods for specific groups [2]. Annex III of Regulation (EC) No 1925/2006 is a list of substances other than vitamins or minerals whose use in foods is prohibited, restricted or under Community scrutiny [5].

EFSA carries out the safety assessments of six substances used as ingredients in food supplements, for which safety concerns were raised either by the EC or Member States: Ephedra species, Yohimbe, hydroxyanthracene derivatives, catechins from green tea, monacolins from red yeast rice and alpha-lipoic acid [2]. If your range includes any of these, ask your auditor how they will verify your current position rather than relying on memory of an older opinion.

Novel food status

If a substance intended to be used in food supplements does not have a history of safe use in the EU before 1997, EFSA is requested to provide a scientific opinion on its safety according to Regulation (EC) No 2015/2283 on novel foods [2]. A novel food is a foodstuff or food ingredient that was not used for human consumption to a significant degree within the European Union before 15 May 1997 [2]. An audit should record how you established that each unusual ingredient is not a novel food.

Additives

Food supplements may contain additives such as sweeteners, colours and coating agents, and only food additives specifically authorised for use in this food category according to Regulation (EC) No 1333/2008 can be added to food supplements [2]. Coating agents for tablets are easy to overlook, so check them line by line.

Label values and tolerances

The Commission has published a guidance document for competent authorities on tolerances for the control of compliance of nutrient values declared on a label with EU legislation [1]. In case of doubt, the guidance document text should be consulted as the official reference [1]. Ask your provider whether their label review uses this document.

National notification

EU countries may, for monitoring purposes, request notification to their competent authority of the placing on the market in their territory of a food supplement product in accordance with Article 10 of the Directive [1]. Requirements therefore vary by Member State, and a single checklist cannot assume one answer for all of them. Confirm the position for each market you sell into.

Use EU data to focus the audit

A good audit is risk-based. The Commission’s food safety site points to several public tools you can use as inputs:

  • The Food and Feed Information Portal, which allows you to search multiple databases regarding the Food and Feed sectors [4].
  • The Rapid Alert System for Food and Feed (RASFF) [4].
  • Monthly reports on EU Agri-Food Fraud suspicions [4].

Reviewing these before the audit helps you decide which ingredients and suppliers deserve the most attention. It also lets you show the auditor that you have already done a risk review.

Questions to ask any food safety audit provider

These questions are advice for your selection process. They are not claims about any particular firm.

  • Scope. Which legal texts will the audit be measured against? Ask whether it covers the rules for food supplements, additives and novel food status, or only general food hygiene.
  • Competence. Who will do the work, and what supplement or botanical experience do they have? Ask for the named individuals, not just the company.
  • Evidence. What will you receive at the end? Look for a written report with findings and a route to corrective action, similar to the recommendation and follow-up approach used in official audits [3].
  • Independence. If the provider also sells you consulting or testing, ask how they separate those activities from the audit opinion.
  • Markets. Will the report address each Member State where you sell, or only one?
  • Lab data. Will analytical results be reviewed, and by which laboratory? Ask for the testing method and the laboratory’s own credentials, rather than accepting a general statement that products were tested.

A short preparation checklist

Before you contact any food safety audit companies, assemble this file:

  1. A formula list showing every vitamin, mineral and source, checked against Annexes I and II of Directive 2002/46/EC [1].
  2. A review of every non-vitamin, non-mineral ingredient against Annex III of Regulation (EC) No 1925/2006 [5].
  3. Written evidence of the novel food assessment for each unusual ingredient [2].
  4. A list of every additive and the basis on which it is authorised for food supplements under Regulation (EC) No 1333/2008 [2].
  5. Label values with the supporting analytical data and the tolerance guidance you applied [1].
  6. A table of the Member States you sell into and any notification requirements for each [1].
  7. A named person in your business who accepts responsibility as the food business operator, since responsibility for safety lies with the operator placing the product on the market [2].

Requirements vary by Member State, and the lists in these annexes have been amended over time [1]. Before you sign an audit engagement, consult a qualified EU regulatory expert on the current texts for your products and target markets.

Sources


Written by Nour Abochama, Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex. Learn more about our team

Talk to our team about EU market entry. Contact us

Nour Abochama

Geschreven door

Nour Abochama

Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex

Chemical engineer with 17+ years of experience in laboratory operations, quality assurance, and regulatory compliance across Europe and North America. VP of Operations at Qalitex (ISO/IEC 17025 accredited US laboratory). Through Care Europe, leads the European entry point to a partner-lab network across the USA, Canada, and local Europe — specialising in USA FDA + Health Canada compliance for European exporters and herbal & supplement testing (a rare expertise on the European continent).

Chemical Engineering17+ Years Lab OperationsISO 17025 ExpertGMP & EU Compliance Specialist
LinkedIn-profiel bekijken →

EU-regelgevingsadvies nodig?

Ontvang deskundig advies van ons SIREN-geregistreerde Franse regelgevingsteam. Tweetalige EN/FR-ondersteuning.

Offerte aanvragen →