CRNUK | Response: Which? Report on High Vitamin Levels

Comments on Which? article on high levels of vitamins and minerals in food supplements

A number of recognised scientific bodies have assessed the safety of vitamins and minerals, with the UK Expert Group on Vitamins and Minerals (UK EVM) in 20032 being the first to publish safe upper levels specifically for food supplements. In Europe in more recent years, the European Food Safety Authority (EFSA) has published their opinions on the safe upper levels of vitamins and minerals, which with a few exceptions are based on total dietary intake3. Food Supplements Europe published an updated model in 20214 determining the safe upper levels for vitamins and minerals in food supplements, which was based on all available internationally recognised scientific data at the time. 

All food businesses have a legal obligation under General Food Law to only place safe food on the UK market. CRN UK’s members take very seriously their legal responsibility to only place safe food on the market and they work as closely as possible to the EFSA and Food Supplements Europe safe upper limits. 
In cases where other companies choose, because of consumer demand, to exceed the safe upper levels defined by the UK EVM for food supplements, there are advisory statements that they need to include on the label5. Although only given in official guidance and not laid down in law, the absence of the advisory statement could be interpreted as meaning that the food is unsafe, as insufficient information is being given to the consumer to ensure their safety.

Food supplements are one of the most highly regulated food products on the UK market. 

What the Which? report highlights is one of the concerns that CRN UK has been raising for many years, namely the lack of proactive enforcement against online marketplaces. 

Since 2009/2010, Local Authority resources have been regularly cut, with reduced government funding leading to reductions in both manpower and financial resources for sampling and testing6. With the need to focus what resources they have on immediate food safety concerns, proactive enforcement against non-compliant foods on online marketplaces is not an area of high priority. 

From the images, it appears that at least one of the products reviewed by Which? was also noncompliant in its labelling. CRN UK has published guidance on seven easy steps to check whether a food supplement is compliant with UK law and this is available for download from our website7. In addition, CRN UK is working alongside other trade organisations to support enforcement in tackling non-compliances on the UK market.

October 2025

1  Which? ‘Supplements in risky doses found across online marketplaces and on the high street’ https://www.which.co.uk/news/article/supplements-in-risky-doses-found-across-online-marketplaces-and-on-the-high-street-akzDa7f6Z4y5

2 Expert Group on Vitamins and Minerals ‘Safe Upper Levels for Vitamins and Minerals’ https://cot.food.gov.uk/sites/default/files/vitmin2003.pdf

3 EFSA Dietary Reference Values: https://www.efsa.europa.eu/en/topics/topic/dietary-reference-values

4 Food Supplements Europe ‘Risk Management Approaches to the Establishment of Maximum Levels for Vitamins and Minerals in Food Supplements in Adults and for Children aged 4-10 Years’: https://foodsupplementseurope.org/wp-content/themes/fse-theme/documents/publications-and-guidelines/FSE-VMs_Risk_Management_Report-May2021.pdf  

5 Department of Health Label advisory statements and suggested reformulations for food supplements: https://assets.publishing.service.gov.uk/media/5a7c4017ed915d7d70d1d961/Advisory_Statements_DH_FINAL.pdf

6 Unchecked.uk The Enforcement Gap: https://unchecked.uk/our-research/enforcement-gap/

7 CRN UK ‘Seven Easy Steps To Assess Non-Compliance of a Food Supplement’: https://crnuk.org/wp-content/uploads/2025/10/Seven-Easy-Steps-To-Assess-NonCompliance-of-a-Food-Supplement-revised-October-2025.pdf

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