The ECMR does not apply. By virtue of their biochemical functions, vitamins are not substitutable on the demand side. On the supply side it would appear that there is no realistic prospect of rapidly switching between the manufacture of different vitamins. Production plants are dedicated to one type of vitamin. On the demand side, these feed and food products cannot be substituted.
Production can be either via a chemical or fermentation process.
It does appear, however, to be easier to switch between the production of B2 for feed and B2 for food and pharmaceuticals with modern fermentation plant, albeit with some sunk costs. The geographic market is at least as wide as Europe and may be world-wide. Vitamins B2 and C are produced in only a relatively small number of plants throughout the world, and consequently are exported widely. Market shares are broadly similar on either a European or a world-wide basis. In 1999, the US Department of Justice imposed record fines on the vitamin industry for the operation of a worldwide cartel.