The import of Lanolin origin Vitamin D3 from outside of Europe could be banned.

On 11th June 2021, the European Commission updated the Q&A section of its Import of Composite Products into the EU document, with specific comment regarding Lanolin-origin Vitamin D3:

2.14. There are no EU-approved establishment listed for the production of lanolin for food purposes. How can I source the vitamin D obtained from lanolin for use in my composite product then?
There is no list of EU-approved establishments for lanolin as there are no specific requirements established for lanolin in Annex III to Regulation (EC) No 853/2004. As a consequence, the vitamin D obtained from lanolin can be sourced from any establishment in the EU or a third country listed for the import of “other products of animal origin” derived from small ruminants, including as regards residues.

The significance of this statement is that classification of Vitamin D3 from Lanolin as a Product of Animal Origin (POAO) means that Lanolin Vitamin D3 from China and India would not be acceptable. Details below:

The Department for Environment, Food and Rural Affairs (DEFRA) confirmed that the correct Legislative route to consider for Lanolin-origin Vitamin D3 is following Article 25(a) of Commission Implementing Regulation (EU) 2021/405, which lays down the lists of third countries, territories and zones thereof from which entry into the European Union of animals, germinal products and products of animal origin (POAO) is permitted. China and India (the primary sources of Lanolin-origin Vitamin D3 in the market) are not on the list.

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