Under the microscope - A review of the testing of Foods for Specific Groups products available on the Irish market
Authors: Farrell L. , Clarke N. , Nic Sheoin S. , Hogan M.G. , Grimes C. , Walsh S. , O’Donovan C.B. 
Published: December 2024

Foods for Specific Groups (FSGs) are a category of products for vulnerable groups including “processed cereal-based foods and baby foods” (PCFBF); “food for special medical purposes” (FSMPs); “infant formula” (IF) and “follow-on-formula” (FOF) as per Regulation (EU) No 609/2013(1). Specific labelling and compositional requirements are set out in the legislation for each of these categories of foods. The Food Safety Authority of Ireland (FSAI) ensures the enforcement of these regulations through service contracts with official agencies including the Health Service Executive (HSE) and the Department of Agriculture, Food and the Marine (DAFM)(2). The aims of this study were to: (1) Identify the categories and quantities of FSGs tested by official agencies in 2022 and (2) Investigate the compositional compliance of products tested.

FSG products were analysed by Official Laboratories (OLs) using accredited methods for potassium, selenium, iodine, zinc, manganese, magnesium, molybdenum, phosphorus, calcium, folic acid, sodium, iron, chromium, vitamin B2 and vitamin B1. Both the measure of uncertainty (MoU) and limit of quantification (LOQ) values were reported. Data was extracted from FSAI’s National Food Safety Surveillance database. Samples were categorised as IF, FOF, PCFBF or FSMPs as per the legislation. FSG products not available for sale in Ireland were excluded. Nutrient concentrations were assessed against the limits permitted in legislation.

Of the total FSG products tested (n92) in 2022, nearly two-thirds (n64) were produced for the Irish market, with the remainder (n28) produced for export. The majority (n51) of Irish products were sampled by the HSE including IF (n10), FOF (n8) PCFBF (n7) and FSMPs (n26). The remaining Irish products (n13) were sampled by DAFM - IF (n6), FOF (n6), and FSMPs (n1). The majority of PCFBF (n6), IF (n14), FOF (n13) tested were deemed compliant, while only 44% (n12) of FSMPs sampled were compliant with the legislation. Possible non-compliance of FSMPs was due to high levels of selenium, chromium, and molybdenum. Possible non-compliance of FOF and IF was due to high levels of selenium. PCFBF possible non-compliance was due to high levels of potassium. However, the analytical MoU values for the nutrients ranged from 0.04 % to 44% which makes judgement of compliance difficult in some instances.

This study gives an overview of FSG products tested by official agencies including their compliance with compositional regulations. Overall, compositional compliance across FSG products is high. However, possible non- compliances were identified due to the wide range of MoUs and their overlap with some permitted limits for certain nutrients. Another issue identified is that some LOQs were higher than the maximum permitted level in legislation. Future work for the FSAI will involve working with the OLs to accredit more sensitive methods, thus facilitating better official controls.