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Food subject to notification – state of the art of the online procedure

Five months after the entering into force of the new electronic notification procedure instituted by the Italian Ministry of Health for food subject to notification, companies need to carry out a careful control of the status of the notifications performed so far for their products to maintain them on the market.

The Ministry of health has in fact also updated the registries reporting the list of notified products.

Currently tow registries are temporarily available for each of the following categories:

  • food supplements
  • formulas for infants
  • food for special medical purposes
  • gluten-free food specifically formulated for people suffering from celiac disease.

However, as of 1st July 2019 one single register will be published and only the products included in it can be marketed in Italy.

The Ministry has considered this procedure as the most appropriate as there are products whose first notification is not recent and that are of no more interest for their holders. These products could also be not compliant with the current provisions.

The regulations of this sector is in fact changing continuously thanks to the progress in scientific knowledge.

Therefore all food business operators (FBO) shall trace back the date of first notification of their products. If it is earlier than 2015 the product need to be notified again using the new electronic procedure. Then the product will be assessed by the Ministry officers, published in the registry and so it can be still marketed in Italy.

The control of the status of the notification is a task fully entrusted to FBO companies marketing their products in Italy. The FBO is the sole responsible for the safety and quality of the product, the publication in the national registry is not a Ministry authorization.

It is therefore essential to carry out a constant examination of the regulations and the relevant updates in order to ensure the compliance of the composition and labelling with the latest requirements.

No later than 30th June 2019 it will be required to resubmit the notification of those products currently included in the sole temporary register (i.e. those notified for the first time before 2015) through the new online system.

This activity of re-notification shall also include a revision of the label and of the composition of the product in order to ensure the relevant compliance with the current regulations.

Di Renzo Regulatory Affairs is able to support Italian and foreign companies in complying with all the necessary requirements. The team dedicated to this sector has appropriate experience and know-how to assist companies in the assessment of the composition and labelling and in the procedure of online notification of food subject to notification.