Whilst the benefits of mushrooms are not a new scientific discovery, they are slowly becoming a popular ingredient in the beauty and wellness space. With cosmetic and food supplement brands featuring mushrooms such as reishi and cordyceps as their hero ingredients, it is unsurprising that these companies want the health and beauty benefits of their signature mushrooms to be heard about. However, a question we are asked a lot at Bloom, is what claims can we make about these ingredients and what are the challenges of including them in our products?
Today we are focusing on the challenges of using mushrooms in food supplement products.
Which mushrooms can I use in food supplements?
Unlike vitamins and minerals, there is no positive list of mushrooms that can be used in food supplements. However, the main concern with using food ingredients that are new and trending is ensuring that they are not deemed as novel food and subject to pre-authorisation.
Novel food is defined as;
food that had not been consumed to a significant degree by humans in the EU before 15 May 1997, when the first Regulation on novel food came into force.
'Novel Food' can be newly developed, innovative food, food produced using new technologies and production processes, as well as food which is or has been traditionally eaten outside of the EU.
Therefore, if an ingredient is deemed novel, it must have a safety assessment and be authorised by the competent authority before it can be placed on the market.
Although mushrooms are certainly not a novel ingredient, specific types of mushrooms coming from outside the EU/UK have been deemed as ‘novel food’ and therefore unless authorised, cannot be used in food supplements.
You can search the EU catalogue of novel foods available online to see if your mushroom is permitted in food supplements.
It is worth mentioning that the EU Novel Food Catalogue lists products of animal and plant origin and other substances subject to the Novel Food Regulation, based on information provided by the EU Member States but it is a non-exhaustive list and serves only as orientation on whether a product will need an authorisation under the Novel Food Regulation. If a mushroom is not listed in the list that does not mean it is not a novel food automatically - companies need to be able to demonstrate evidence of previous use as a food.
Are mushrooms considered as medicines?
A quick google search will tell you that mushrooms are deemed a ‘superfood’ and have a plethora of benefits for your health including increasing immunity, stimulating a healthy gut and even going as far as decreasing the risk of cancer!
Unfortunately, these claims and any claim that states they can treat, prevent or cure disease are all medicinal and strictly not permitted for food supplements.
A food supplement can only supplement the normal diet and should only have a nutritional or physiological effect.
Generally, food supplement brands selling mushroom-containing formulas, rely on the inclusion of the ingredient alone to be enough of a claim to attract consumers who are looking for this particular superfood.
Can I make health claims on mushrooms?
In the UK and EU, food supplements are strictly regulated under various pieces of legislation. One area where there is very little room for creativity is on claims. You may notice whilst perusing the aisles of any health shop that you see the same claims repeated on everyone’s packs. This is because health and nutrition claims are regulated under Regulation (EC) No 1924/2006 (Nutrition Health Claims Regulation and its retained UK law). Health claims state a relationship between food and health and to use such claims, they must be listed as authorised in the EU register (which has also been adopted by the UK) and must meet conditions of use associated with the claim. For mushrooms there are no authorised claims within the register and therefore strictly speaking, we cannot make health claims on the inclusion of mushrooms in a food supplement formula except in rare cases where an ‘on hold’ claim may be available providing suitable data is available.
What can I actually say about my product?
Whilst this is all looking relatively bleak, as mentioned above, consumers are aware from online hype, the benefits of mushrooms and will seek products that simply contain these ingredients. It is worth bearing in mind that whilst printed assets will not have the space to be able to contain much marketing information, you can provide more information and a marketing story to the consumer via digital platforms such as social media and web copy where space is less limited (all the time keeping in mind that the MHRA [medicines authority in the UK] can and will enforce on unlicensed medicinal claims online and on social media– so ensure you only make compliant claims!).
If you would like any regulatory assistance with your food supplements that contain mushrooms or any other superfood, please do not hesitate to get in touch.
Our next blog: Let us know if you would like us to dissect the challenges of using mushrooms in cosmetics!
Written by Laila Manshi