Untitled

Item of PROY‐
NOM‐051
3.19
Definition:
“Dietary fibre”
5.1.1
“Energy
calculation”
5.1.4 “Energy
content
polyalcohols
and
polydextrose”
Proposal Justification
We support the Dietary
Fibre definition of Codex
Alimentarius including DP 3
– 9 as stated in Footnote 2.
Carbohydrates: 4 kcal/g –
17 kJ
Proteins: 4 kcal/g – 17 kJ
Fats: 9 kcal/g – 37 kJ
Alcohol: 7 kcal/g – 29 kJ
Organic acids: 3 kcal/g – 13
kJ
Isomalt: 2.0 kcal/g – 8 kJ
Lactitol: 2.0 kcal/g – 8 kJ
Maltitol: 2.1 kcal/g – 8 kJ
Mannitol: 1.6 kcal/g – 6 kJ
Sorbitol: 2.6 kcal/g – 10 kJ
Xylitol: 2.4 kcal/g – 10 kJ
HSH (maltitol syrup): 3.0
kcal/g – 12 kJ
SSS/WCS/IML
Regulatory Affairs
October 22 nd , 2009, page 2 / 4
Regarding this definition we want to stress that we support
it, provided that as foreseen in footnote 2, carbohydrates
with a DP (degree of polymerisation) of 3 to 9 monomeric
units are included into the definition.
Non‐digestible oligosaccharides, e.g. oligofructose do
behave as dietary fibres, and these properties do not
change at DP =10 or higher. It will also harmonise the
Mexican DF definition with almost all other definitions, as
proposed worldwide, including EU, EFSA, Institute of
Medicin (US), FSANZ, ILSI, AACC…
For those ingredients, for which the scientific basis for an
individual energy value is established, this individual value
should be used.
Scientific evidence is available for the following energy
conversions factors:
‐ Inulin/oligofructose: in the US, a value of 1.5 kcal/g is
used. Further support for this value is given in Annex 2.1.
and Annex 2.2.
For those ingredients, for which the scientific basis for an
individual energy value is established, this individual value
should be used.
Having the NAFTA in mind, where US and Canada accepted
deviated caloric values for polyols, if necessary scientific
substantiation is available, it should also be appropriate as
well for Mexico to handle the same caloric values:
‐ US: each polyol has its own FDA notified energy
conversion factor, based upon a scientific evaluation by
FASEB (Federation of American Societies for Experimental
Biology; 1994; “The Evaluation of the Energy of Certain
Sugar Alcohols used as Food Ingredients”) [Annex 3.1].
“Letter of no objection” received for caloric value of
2.0 kcal/g for isomalt [Annex 3.2].
‐ Canada: has confirmed the use of 2 kcal/g (http://www.hc‐
sc.gc.ca/fn‐an/securit/addit/sweeten‐edulcor/polyols_polydextose_factsheet‐
polyols_polydextose_fiche‐eng.php)