It has come to our attention that the Danish Veterinary and Food Administration (DVFA) considers vitamin D products (food supplements) as products of animal origin, as vitamin D typically is extracted from sheep's wool. Vitamin D products have not previously been considered as products of animal origin by the DVFA.
The consequence of the Administration considering vitamin D as an animal ingredient is that the manufacturer of a food supplement containing vitamin D must be authorized and the supplement must be labelled with the animal ID tag.
The DVFA is referring to an EU interpretation of the EU hygiene regulation No. 853/2004. Article 4 concerning the authorisation requirement refers to Annex III, Chapter V, Section XVI on highly refined products. Vitamin D is not listed in this section. Still, since D vitamin originates from sheep’s wool, the DVFA interprets that the handling of Vitamin D as an ingredient in a food supplement also is covered by the relevant authorization requirement. We are interested to understand whether your local food authority also has the same interpretation with the consequence that D vitamin food supplements are considered as products of animal origin.
We understand the view that handling of sheep’s wool is covered by the hygiene regulation. Though, to apply the regulation to an extracted ingredient processed into D vitamin which is added to a supplement seems to us as a wide interpretation of the specific section of the annex III in the regulation. For your information, the DVFA applies the same interpretation to fish oil and collagen products.