Академический Документы
Профессиональный Документы
Культура Документы
Contents
Foreword................................................................................................... 04 Introduction............................................................................................. 06 Executive summary................................................................................ 07 An insight into the nutraceuticals market of India
Section I: Nutritional status of the population of india....................................10 Section II: Nutraceuticals market: global and India.........................................24 Section III: Way forward............................................................................... 48
Foreword
Ajit Singh Chairman- FICCI Task Force on Nutraceuticals Chairman- ACG Worldwide (formerly Associated Capsules Group) President- Health Foods and Dietary Supplements Association (HADSA) Dear reader, Nutraceuticals as they are called in industry parlance cover a basket of products from dietary supplements to probiotic and energy drinks to cholesterol and fat free foods among others. Increased discretionary spending, changing lifestyles and growing awareness among Indians about healthy living are accelerating the growth of this Industry. Despite the huge potential, Indias share, with reference to the global Nutraceuticals market is still minimal. FICCI is one of the apex chambers of commerce of India, which has empowered Indian businesses in the ever changing and challenging times, to step up their competitiveness and enhance their global reach. FICCI acts an effective change agent and has been working diligently towards influencing the government to bring about necessary policy changes to give impetus to this sector. FICCI has played a catalytic role in many sectors where India commands a leadership position today. HADSA is a non-profit trade association which not only represents the interests of manufacturers, suppliers and health-care products, but also supports science-based environment for responsible marketing of nutritional supplements. FICCI and HADSA have come together to provide a platform to the industry to share their concerns, flag issues, and discuss strategies to compete globally in the field of Nutraceuticals, Functional Foods and Dietary Supplements. Our vision is to accelerate Indias share of 0.9% of the worlds US$117 billion nutraceuticals, functional foods and dietary supplements market to a sizeable number in the next few years. Considering the huge growth potential of the Indian nutraceuticals industry, I envision India to be ranked among the top players such as USA, Europe and Japan which are the current market leaders. This FICCI - Ernst & Young knowledge paper has synergized the available body of knowledge with the current business realities and suggested strategies to increase Indias share of the global Nutraceuticals market.
Dear reader, Nutrition related risk factors contribute to more than 40% deaths in developing countries and India is no exception. Nutrition related disorders force back its GDP by at least one percentage point. India is reeling under the burden of nutrition deficiencies with one-fifth of the Indian population lacking the purchasing power to even consume a diet sufficient in calories, let alone nutrients; and an astounding 570 million consuming sufficient or excess calories, but lacking adequate intake of nutrients. In fact, 60% of this section consumes higher than normal calories, with a disproportionately high fat intake and this could make India the future cardiovascular and diabetes capital of the world. The key factor responsible for these severe inadequacies in nutrient intake has been a significant change in lifestyle caused by rapid urbanization and growing modernization in methods of food processing and cooking. As these changes are irreversible in nature, any agenda to foster "quality healthcare for all" is incomplete without supplementing it through nutritional interventions. Unless such interventions are introduced, the gap in nutrient intake will continue to widen. Thus, it should be a part of the nations critical agenda to ensure that every citizen has access to Nutraceuticals - products which supplement the diet to provide nutrition over and above regular food. It is a non-negotiable imperative that nutraceuticals cease being just a luxury and emerge as a necessity for the Indian populace. However there are some impediments in the path to achieving this aspiration: The prices of most nutraceutical products are high, severely limiting growth in demand, especially since India is a price sensitive market There is a lack of credibility of the benefits of nutraceutical products in the consumers minds, further aggravated by unsubstantiated claims The lack of regulations to govern nutraceuticals acts as a deterrent for committed nutraceuticals players, both Indian and international, to enter the Indian market "Nutraceuticals Critical supplement for building a healthy India", a FICCI Ernst & Young initiative is a comprehensive study assessing the current and latent potential of the nutraceuticals market in India, the critical impediments to convert latent opportunity into a market and the future imperatives for the government and private sectors. The report suggests concerted and implementable strategies to the government and private sectors which, if implemented, would assist in achieving the latent potential of nutraceuticals in India and at the same time addressing the diverse nutritional needs of the population. We encourage you to explore, invest and partner in the Indian nutraceuticals market which truly stands at an inflexion point, poised to grow.
Introduction
Quality healthcare is the foundation of any prosperous nation. Nutrition care, which forms an integral part of preventive healthcare, is undergoing a transformation in India. Today, food alone is unable to fully service the nutrition needs of the body. Thus, supplementing it with lifestyle interventions has become a non-negotiable imperative not only to enhance health but also to reduce dependency on curative measures. While lifestyle interventions can be manifold, this report is focused on those formulations or foods that can supplement normal diet (called " Nutraceuticals ") and does not cover services that can be offered in this regard. Also this report covers the domestic nutraceuticals market and not the export market potential of Indian nutraceuticals. This document aims to present: The nutritional status of Indians, their dietary patterns and underlying drivers An assessment of the current and latent potential of the nutraceuticals market in India Critical impediments in achieving latent potential, and Way forward for the government and private sector The viewpoints and conclusions presented in this report are an outcome of discussions with various stakeholders, regulators, key opinion leaders, subject experts, data available in the public/propriety domain and our industry understanding. An attempt has been made to provide a reference document for existing private Indian and global nutraceutical players, new entrants, potential investors and regulators to explore and assess the nutraceuticals opportunity that India presents.
Executive summary
Nutrition is a fundamental need. Various risk factors related to health result from an imbalance in nutrition. Together, these factors contribute to more than 40% of deaths and 30% of the overall disease burden in developing countries. In India, nearly 20% of the total population and 44% of young children (below 5 years of age) are undernourished, numbers which are significantly higher than even the poorer subSaharan African countries. Iron deficiency anemia during pregnancy accounts for one-fifth of maternal deaths in India and the prevalence of this deficiency in women has alarmingly increased from 52% in 1998 to 56% in 2006. Iodine and Vitamin A deficiencies in India are still above the WHO specified desired levels. Annually as many as 0.3 million children succumb to Vitamin A deficiency related diseases. The impact of these deficiencies is a productivity loss of around one percentage point of Indias GDP. The nature of Indias nutrition concerns are three fold On one hand is the undernourished population (380million) with majority having inadequate purchasing power to even consume a diet sufficient in calories, let alone take sufficient nutrients. Their challenge is to meet foundation needs to maintain normalcy of being. These needs would have to be addressed by government programs with the private sector playing a supportive role. On the other hand is the huge population (570 million) that is nourished in calorie intake but not in terms of nutrient intake. This segment would typically include lower middle to upper class population with sufficient purchasing power but probably low awareness about their nutrient requirements, leading to unmet condition specific needs in addition to foundation needs. In fact, there are 340 million in our population (30% in urban and 34% in rural areas) who consume more than the recommended number of calories with higher than recommended levels of dietary fats and could be the largest contributor in making India the future cardiovascular and diabetes capital of the world. While there are several factors that have contributed to these severe inadequacies, the key ones are increased urbanization, larger working class population and growing affluence. These factors have resulted in a shift of dietary habits from consuming micronutrient rich foods such as fruits and vegetables to consuming more of fat-rich calorie foods. The third population segment (80 million) is one which consumes nutrients and calories more than the norm due to their enhanced physical requirements because of their chosen lifestyles and interest areas such as professional sports, heavy exercises and extensive outdoor field work. This would lead to a greater need for nutrition, in addition to some condition specific and foundational needs. Many of the factors affecting nutrition related concerns are irreversible that have led to natural sources of nutrients being consumed in insufficient quantities. Hence, the requirement of external intervention, that can supplement diet to help prevent nutrition-related disorders and promote wellness over treatment of illness, has become critical. Such products are collectively called as nutraceuticals. As a concept, nutraceuticals is in its stage of infancy with several developed countries having defined it only in last 15 years. India has already defined it in the Food Safety and Standards Act of 2006 but is yet to implement it as the rules are not completely framed. Of the global nutraceuticals market of USD117 billion (INR5148 billion), India has less than 1% share and is estimated to be around INR44 billion in size. The three broad categories within nutraceuticals are - functional foods, functional beverages and dietary supplements. While the global market is expected to grow at a CAGR of 7%, the Indian industry has been growing much faster at a CAGR of 18% for the last three years, driven by functional food and beverages categories that are growing faster than the dietary supplements category due to wider distribution across FMCG channels as well as aggressive mass marketing. There are four key drivers to this growth an increased affluence of the ever-growing working population, a reduced affordability of sick care that in turn drives consumers towards wellness, an increased physician awareness and media penetration and finally, an increased accessibility to newer distribution channels. However, the latent market in India is two to four times the existing market size (between INR89 billion and INR172 billion) with nearly 148 million potential customers. The market is latent because there some major impediments to effectively tap this market. These are High prices of nutraceuticals when compared to conventional foods especially since India is a price sensitive market.
Lack of credibility of the benefits of nutraceuticals in the minds of consumers, further aggravated by the unsubstantiated claims made by certain products. Regulatory framework not yet implemented despite the act being in place for over three years plus inadequate resources available for implementation. This lack of regulations to govern nutraceuticals acts as a deterrent for large foreign players planning to enter the Indian market.
Measures should be taken to ensure availability of adequate resources for efficient implementation of laid out rules. These measures could include gearing-up of staff strength, specialized training and increasing the number of food testing laboratories from an estimated 250 laboratories currently to a required number of 500 laboratories. Encourage research and development in the field of nutrition and deploy Public Private Partnership (PPP) models to serve needs of the undernourished segment of population The government should establish a dedicated fund for focused nutraceuticals research and support nutraceutical players by providing them with research infrastructure Ensure that a larger population gets the benefit of nutraceuticals For this, the government should explore PPP to deliver the benefits of nutrients to the undernourished section of the population.
Section
10
Summary
Various risk factors related to health result from an imbalance in nutrition. Such imbalances in India are widely prevalent leading to adverse outcomes. The impact of these outcomes is a productivity loss of around 1% point of Indias GDP Analysis of our dietary intake reveals nutritional imbalances across most segments of population : Majority of the undernourished population (380 million) faces a challenge to meet foundation needs to maintain normalcy of being. There is a huge population (570 million) that is nourished in calorie intake but not in terms of nutrient intake. They face the challenge of meeting condition specific needs in addition to foundation needs and could be the largest contributor in making India the future cardiovascular and diabetes capital of the world. There is another population segment (80 million) which consumes nutrients and calories more than norm due to their enhanced physical requirements. Since many of the drivers underlying nutrition related concerns are irreversible and natural sources of nutrients are being consumed in insufficient quantities, the requirement of an external intervention has become a non-negotiable imperative that can supplement food diet to help prevent nutrition related disorders and promote wellness rather than treat illness. Such products have collectively been called as Nutraceuticals
11
More than forty percent deaths in developing countries are attributable to risk factors linked to nutrition
8 of the top 15 risk factors are related to nutrition and contribute to nearly forty percent of total deaths and thirty percent of total disease burden in developing countries like India
15 leading risk factors in developing countries with high mortality rates*
Risk factors 1 Underweight
Unsafe sex
Percentage of disease burden attributable to risk factors 15% 10% 2% 6% 2% 2% 4% 1% 3% 3% 3% 1% 2% 1% 1% 0% 4% 8% 12% 16%
2 Blood pressure
Unsafe water, sanitation and hygiene
3 Cholesterol
Tobacco Indoor smoke from solid fuels
4 Low fruit and vegetable intake 5 Zinc deciency 6 Vitamin A deciency 7 Iron deciency
Physical inactivity Alcohol
8 Overweight
Unsafe healthcare injections
Source: World Health Report 2002, WHO * Notes: Includes 66 countries. Key countries include South Africa, sub-Saharan African countries, Iraq, Egypt, Pakistan, Peru, South Korea, India, Myanmar, Nepal Other risk factors include physical inactivity, risk factors for injury, overweight, lead exposure, climate change, childhood sexual abuse, illicit drugs, urban air pollution, noise, airborne particulates, ergonomic stressors, carcinogens which contribute to the remaining 30% deaths and 44% disease burden
Food is composed of a wide distribution of nutrients, which have very specific metabolic effects on the human body. Nutrients are of two types - macro-nutrients and micro-nutrients Denition of key nutrients
Includes carbohydrates, fats & oils, proteins & amino acids Supply energy, and these essential nutrients are needed for growth, maintenance, and activity Needed in large amounts
Macro-nutrients
Nutrients
Includes vitamins, trace minerals (iron, zinc) Vitamins act as catalysts that help to trigger other reactions in the body while trace minerals contribute to the synthesis of glycogen, protein, and fats Needed in relatively small amounts
Micro-nutrients
13
44% of Indian children are underweight1, which is much higher than most comparable countries. Further, the proportion of underweight children has reduced only marginally in last 10 years, showing slow pace of improvement. Other related adverse health outcomes are stunting2 and wasting3 and the proportion of these is also alarming at 38% and 19% respectively. Being underweight may reduce a childs IQ by 5%, while stunting may reduce it by as much as 11%. Percentage of underweight children below 5 years of age Underweight 43.5
1.4 Russia
3.7 Brazil
Maternal mortality rate in India is much higher than that of comparable countries. About 20-40% of maternal dealth in India are due to anemia, the proportion of which has increased in the last decade. Maternal mortality rate per 10,000 live births, 2005
45
Iron deciency
79 52 56
Brazil
India
2005-06
* Children between 6-35 months of age ** Married women in the age group of 15-49 years
Vitamin A deciency
India
* Pre-school children
0.5%
Prevalence of vitamin A deciency is much above WHO cut off levels resulting in approximately 330,000 child deaths every year
Source: NFHS, Report of the Working Group on Integrating Nutrition with Health, 11th Five Year Plan (2007-2012) , India Micronutrient National Investment Plan 2007-2011 1 2 3 Underweight: Children under 5 years whose weight-for-age is less than -2 Standard Deviation (SD) Stunted: Children under 3 years whose height-for-age is less than -2SD disorder) Total goiter rate (Iodine deciency Wasted: Children under 3 years whose weight-for-height is less than -2SD
10%
14 Iodine
deciency
Prevalence of goiter caused due to Iodine deciency is twice the WHO cut off levels, adversely impacting Nutraceuticals Critical supplement for building a healthy India intellectual capacity by upto 15% 5%
deciency
India
* Pre-school children
Source: NFHS, Report of the Working Group on Integrating Nutrition with Health, 11th Five Year Plan (2007-2012) , India Micronutrient National Investment Plan 2007-2011
Iodine deciency
India
Prevalence of goiter caused due to Iodine deciency is twice the WHO cut off levels, adversely impacting intellectual capacity by upto 15%
Source: Report of the Working Group on Integrating Nutrition with Health, 11th Five Year Plan (2007-2012), India Micronutrient National Investment Plan (2007-2011 )
India has the largest burden of CVD and largest number of diabetes patients in the world Cardiovascular diseases DALYs (millions)
24.5 11.8 4.1 Brazil Russia China India 4.6 4.6 28.9 20.8
Russia
Source: WHO 2000
Brazil
China
India
Adverse outcomes are estimated to cost nearly 1% point to Indias GDP and so improvement in nutrition status is a critical part of the countrys agenda for progress An estimate of the cost of productivity lost on account of mortality due to nutrition related disorders was estimated to be 0.85% of the GDP in 2004 and is expected to increase upto 1.2% of India's GDP by 2015
Source: WHO 2009, Popkins et. al (2001), Ernst & Young analysis
15
Analysis of India's dietary patterns provides a few key insights into the nutrition levels and needs of the population
Nearly 20% of the Indian population is undernourished implying a low calorie as well as nutrient intake
India lags behind not only other developing countries but also some sub-Saharan African countries in terms of undernourishment
Russia
Brazil
Nigeria
China
Uganda
India
Source: Global Hunger Index, International Food Policy Research Institute 2008
Even in the population that shows sufficient calorie intake, the micronutrient consumption is not at desired levels
While the intake of calorie rich foods may be high, micronutrient rich foods are being consumed in low proportions. As a result, significant micronutrient deficiencies exist in urban as well as rural areas
101% 83%
102%
RDA 81% Zinc 56% 65% 60% 58% 83% 90% 0% 20% 40% 60% 80% 100% 120%
71%
Vitamin A 33% Iron Cereals Edible oil Milk & milk Sugar products Calorie rich Rural Urban Pulses Vegetables Fruits Micronutrient rich
16
At the same time, there is a growing population (340 million) which is consuming excess calories, with a disproportionately high level of fats
Nearly 340 million people - 30% of the population in urban areas and 34% of the population in rural areas - consume calories more than the norm
Percentage of population by level of calorie intake as a percentage of norm level*
11% 19% 13% 21% Calorie intake as a percentage of norm >150% 23% 23% 17%
Recommended range
Calories derived from fat as percentage of total calories for the excess calories consuming population
70%
32%
66%
Rural
120% 150%
Average
21% 16%
Rural
Source: NSSO 2004-05 *2700 kcal per consumer unit per day
Urban
Also, there is a growing fitness need which has led to rapid rise in slimming centers and gymnasiums. This is driving enhanced nutrition requirements for this segment of the population
Growth in slimming centers and gyms market (INR billion)
4.5 CAGR 33% 1.9 CAGR 23% 2.5 4.6
Gyms
17
18
These patterns can be mapped into distinct population segments based on their food and nutrient intake
Sufcient/ excess
Over-nourished 80 million
Micronutrient intake
Decient
Adequate/excess
Calorie consumption
Source: NSSO 2004-05, India Micronutrient Initiative Plan 2007-2011, Ernst & Young analysis
Market size of this segment of the population is assumed to be insignicant as they are calorie decient but micronutrient sufcient implying that they could be an extremely health conscious segment with dependence on very low calorie foods but still managing to derive sufcient micronutrients 1 2 Population as per NSSO 2006-07 report As per most recent national initiative called the Micronutrient National Investment Plan 2007-2011, inadequate consumption of fruits and vegetables is a key reason for deciency of essential micronutrients. For the purpose of estimating decient and sufcient nutrition intake population segments, it has been assumed that persons who consume fruits and vegetables combined less than ICMR norm of 175 gms/ day would be decient in micronutrients The entire population below the food poverty line (as dened in the report of the National Commission on Macroeconomics and Health, 2005) has been considered as undernourished, irrespective of level of calorie consumption
19
Nutrition related needs of population segments can be viewed as a hierarchy of foundation, condition specific and enhancement needs
Enhancement needs
Foundation needs
20
While food has been the major source for servicing these needs in the past, with growing modernization some traditional ways are being given up, thereby adversely impacting balanced nutrition
Nutrients concerned Water soluble vitamins (Vitamins B and C) and minerals Proteins, minerals and Vitamin B complex Calcium, Iron, Thiamine and Niacin Iron
Adverse impact on nutrient intake due to modernization In the modern blanching processes adopted there is loss of ascorbic acid, water soluble vitamins and minerals just before freezing the vegetables Milling and polishing of cereals significantly reduces protein, mineral and Vitamin B complex Heavy milling and poor storage conditions result in a considerable loss of Calcium, Iron, Thiamin and Niacin Organic iron from the conventional karai is stated to fortify the food cooked in it a benefit absent in modern cookware like non-stick and teflon coated utensils Copper, although required in minor amount, is not gained from the stainless steel utensils used today. Deficiency is known to cause chronic diarrhea, mal-absorption problems and reduced immunity
Manual processing of cereals Fresh grinding of wheat at home Cooking in iron karai
Copper
Source: Srilakshmi B. 2003 Food Science, American Association of Cereals Chemists, Carribean Home Economics, Ernst & Young research
There is an ever widening gap in nutrient intake due to which "normal life is no longer normal"
21
Thus, the pressing need to complement food with external nutritional interventions has become a non-negotiable imperative to avert curative measures
While such interventions can be manifold, this report is focused only on products that can fulfill this role. These products have been collectively referred to as "Nutraceuticals" Nutraceuticals, an emerging concept, can be broadly categorized as products which are extracted from natural sources (nature-like) or manufactured synthetically (man-made), which supplement the diet to provide nutrition over and above regular food and help prevent nutrition related disorders.
Curative
Traditional medicine
Pharmaceuticals
Usage
Food
Preventive
Nutraceuticals
Natural
Nature-like
Man made
Source
Ideally, intake of nutrients through food would have been sufficient to prevent curative measures such as pharmaceuticals and traditional medicine to a large extent However, in the absence of requisite nutrition through food, an external intervention in the form of nutraceuticals has become imperative
22
Section
II
24
Summary
As a concept, Nutraceuticals is in its stage of infancy with several developed countries having defined it only in last 15 years Of the global nutraceuticals market of USD117 billion (INR5148 billion), India has less than one percent share and is estimated to be around INR44 billion in size. But it has been growing much faster than global rates at a CAGR of 18% for the last 3 years driven by functional food and beverages categories There are four key underlying drivers for this growth: Affluence of working population with changing lifestyles Reducing affordability of sick care, driving consumers towards wellness Increasing physician awareness and media penetration Increased accessibility due to emergence of newer distribution channels However, the latent market in India is two to four times the existing market size (between INR89 billion and INR172 billion) with nearly 148 million potential customers. The market is latent because there some major impediments to effectively tap into this market. These are: Regulatory framework not yet implemented Inadequate resources for implementation of regulations High prices of nutraceuticals Lack of credibility of nutraceuticals
25
While some countries define nutraceuticals based on the segments it constitutes, others define it based on the benefits it provides to the consumers. There is also no clear consensus on inclusion or exclusion of traditional medicines. Further, some of the most developed countries have implemented legislation as recently as in 2004, so the concept itself is recent in such countries
The nomenclature for nutraceuticals varies across countries with Canada naming them as "Natural Health Products", USA calling them "Dietary Supplements" and Japan naming them "Foods for Special Health Use" (FOSHU) The definitions even by regulating authorities in different countries range from general to highly elaborate: There are distinct definitions and regulations for dietary supplements and functional foods in USA, Canada and Europe. Whereas in Japan, both dietary supplements and functional foods are governed under the same set of regulations.
USA and Canada actually list the constituents that a product must have to be called a nutraceutical, whereas Europe and Japan just provide general guidelines on the properties that a product should have to be called a nutraceutical. Traditional and herbal medicines are included in the definition of dietary/nutritional supplements in Canada. Japan does not mention traditional herbal medicines under FOSHU foods. USA includes herbs and botanicals in its definition. The Indian definition (as per the Food Safety and Security Act 2006) lists down the ingredients that a product should have, and it also specifies general properties of nutraceuticals. Traditional medicines though have been excluded from the definition.
Source: US Food & Drug Administration website; Health Claim Evidence Requirements in Japan,(Yamada et al); Health Canada Natural Health Products Directorate website; European Union Directive; European Parliament directive on food supplements; Department of Health & Ageing, Therapeutic Goods Administration, Australia website; The Russian Federation Chamber of commerce and Industry website, Food Safety and Security Act of India, 2006
26
Canada
Known as: Natural Health Products Governed by: Food and Drugs Authority Implemented in: 2004 The denition covers: Vitamins and minerals Herbal remedies Homeopathic medicines Traditional medicines such as traditional Chinese medicines Probiotics Other products like amino acids and essential fatty acids
Russia
Known as: Biologically active food supplements Governed by: Ministry of Health & Social Development Implemented in: 1997 The denition covers : Nutriceuticals (Vitamins, Minerals, amino acids, dietary bers) Para-pharmaceuticals ( bio-avonoids, alkaloids, essential oils, polysaccharides)
USA
Known as: Dietary supplements Governed by: Food and Drugs Authority Implemented in: 1994 The denition covers products (other than tobacco ) containing: Vitamins Minerals Herb/botanicals Amino acids Concentrate, metabolite, constituent, extract
Australia
Known as: Complementary medicines Governed by: Dept. of Health and Ageing Implemented in: 1991 The denition covers: Herbal medicines Vitamins and minerals Nutritional supplements
Japan
Known as: Foods for Specic Health Use Governed by: Japan Health and Nutrition Food Association Implemented in: 1991 Functional foods are foods that can have three functions: Nutrition Sensory satisfaction Physiological improvements
India
Regulation: Food Safety and Standards Act (FSSA) Effective from: Passed in 2006, yet to be implemented Foods for special dietary use are specially processed or formulated to satisfy particular dietary requirements which exist because of a particular physical or physiological condition or specic diseases and disorders and which are presented as such wherein the composition of these foodstuffs must differ signicantly from the Indian Standard (IS) composition of ordinary- foods of comparable nature, if such ordinary foods exist and may contain one or more of the following ingredients, namely : Plants or botanicals or their parts in the form of powder, concentrate or extract in water, ethyl alcohol or hydro alcoholic extract, single or combination Minerals or vitamins or proteins or metals or their compounds or amino acids ( in amounts not exceeding the Recommended Daily Allowance for Indians) or enzymes (within permissible limits) Substances from animal origin Dietary substances for use by human beings to supplement the diet by increasing the total dietary intake
Source: US Food & Drug Administration website; Health Claim Evidence Requirements in Japan,(Yamada et al); Health Canada Natural Health Products Directorate website; European Union Directive; European Parliament directive on food supplements; Department of Health & Ageing, Therapeutic Goods Administration, Australia website; The Russian Federation Chamber of commerce and Industry website, Food Safety and Security Act of India, 2006
27
Drawing on the common aspects from the definitions across different countries, for the purpose of this report, definition of "Nutraceuticals" has been restricted to
Formulations or foods with health benefits that are taken orally in addition to the normal diet and can even be taken over prolonged periods in concentrations which are lower than the Recommended Daily Allowance (i.e. below the therapeutic range) to: Supplement the diet to help prevent nutrition related disorders Provide structure/function support that may help prevent specific diseases like diabetes, cancer, obesity through beneficial and proven effects that go beyond the known nutritional effects Fulfill special physiological needs of the body such as like pregnancy, lactation, sports, infancy and sedentary lifestyle
Further to this definition, following 3 categories have been considered under the purview of "Nutraceuticals"
Foods that have specic physiological benets and/ or reduce the risk of chronic disease
Key product segments Nutrition fortified foods like fortified flour, fortified oil, fortified malted powder Probiotic foods like yogurt
Dietary supplements provide nutrients that are missing or are not consumed in sufcient quantity in a person's diet Key product segments
Functional beverages
Antioxidants Tonics Herbal extracts like Chyawanprash, non-herbal extracts like cod liver oil
Liquids that quench thirst along with replenishing minerals, provide energy, prevent ailments, and promote healthy life styles
Key product segments Sports and energy drinks Fortified juices Glucose powder
28
The global nutraceuticals market is estimated at USD117 billion, (INR5148 billion) of which Indias share is a meager 0.9%
US, Europe and Japan are key markets for nutraceutical consumption
Geographic split* Switzerland 3% Italy 3% Japan 22% Rest of EU 6%
UK 2%
US 36%
Globally, this market is expected to reach USD177 billion in 2013 growing at a CAGR of 7% driven by the fast growing dietary supplements category
Global nutraceuticals market
200 180 160 140 USD billion 120 100 80 60 40 20 0 Functional foods 40 2007 Functional beverages 39 57 38 49
% R7 AG C
71
The dietary supplements category is expected to be the fastest growing product category globally with a CAGR of 11%.
29
The nutraceuticals market in India is estimated to be at least INR44 billion with functional foods forming largest category with 54% share
43.9
Functional beverages
6.0
22.7
0.5
3.0 1.0
5.2
Note: All gures are in INR billion. Source: Primary interviews, Industry sources, Ernst & Young analysis
The functional foods market is the largest followed closely by the dietary supplements market which has a 32% market share. The functional beverages market in India is relatively nascent.
Note: While we have not validated the efficacy of the products constituting these segments nor the studies backing their claims, the attempt here has been to estimate the market size of those segments where some research exists to substantiate health or nutrition claims. Segments such as iodized salt have been excluded from the market sizing exercise as large scale fortification of these products has led to consumption not primarily for the fortification benefits but for regular food value. Please note that in the energy drinks market, caffeine rich products have not been included.
30
Nutraceutical products aim to fulfill different consumer needs based on which they can be classified as Enhancement segments, Condition specific segments and Foundation segments
High protein supplements Energy drinks Sports drinks Glucose drinks Antioxidants Vitamin supplements Mineral supplements
Enhancement segments There are a few product segments such as sports and energy drinks catering to health enhancing needs of the consumers
Condition specic segments Product segments like vitamin supplements, mineral supplements etc. cater to the needs arising out of condition specic health concerns
Macronutrient supplements Nutrition fortied foods, e.g., (fortied our) Probiotic foods, e.g., (yogurt) Extracts, e.g., (chyawanprash) Child* Young adult* Adult*
Foundation segments Foundation products segments cater to the consumer trend towards wellness and healthier lifestyles. These product segments promote general well being are largely targeted at all age groups. Old age*
Lifecycle stages
*Note: Child: 0 4 years; Young Adult: 5 14 years; Adult: 15 59 years; Old Age: 60+ years Source: Ernst & Young Analysis
Though a product category can be classified into a specific need-segment based on its predominant use, some product types may transcend across need-segments For example cod liver oil, along with meeting foundation needs of boosting the immune system, will also cater to prevention needs of lowering cholesterol
31
...And product segments catering to foundation and condition specific needs are the largest and growing the fastest
While the global industry is growing at a CAGR of 7%, the Indian industry has been growing at a CAGR of 18% in the last 3 years
Glucose drinks Enhancement needs Sports and energy drinks 0.3 0.5 Mineral supplements 3.1 Tonics 1.4 2.4 Vitamin supplements 3.8 1.2 2.5 Fortied oil Fortied malted powder 0%-10% 11%-20% 21%-30% 4.6 15.7 5.2
Antioxidants
0.9
Foundation needs
Macronutrients
2.2
Fortied our
Dietary supplements
Functional foods
Functional beverages
The functional food and beverages categories consisting of nutrition fortified foods, sports and energy drinks, fortified juices and probiotic foods are growing faster, driven by wider distribution across FMCG channels as well as aggressive mass marketing
32
4 3
18%
ess aren Aw
Increasing physician awareness and media penetration
ce uen Af 1
Afuence of working population with changing lifestyles
Affluence: Increased affluence of the ever-growing working population with changing lifestyles is leading to changes in dietary habits
6% 22%
9% 26%
11% 30%
65%
58%
<15 years
15-60 years
Growing disposable income and lifestyle changes such as shift in dietary habits towards higher fat has resulted in increasing incidences of chronic disorders. This in turn is likely to fuel the demand for nutraceutical products.
34
Affordability: Reduced affordability of sickness related expenditure is driving consumers towards wellness
Average cost of in-patient treatment both in rural and urban India has doubled in the last decade
Average cost of inpatient treatment
12000 10000 8000 INR 6000 4000 2000 0 Rural Urban 3900 6900 4800 10800
Global
1995-96
2004-05
These factors are driving consumer towards health and wellness related services in order to lead healthier lifestyle and prevent spiralling sick care costs.
Share of consumers wallet on healthcare expenditure is expected to go on increasing
100 80 Share of wallet 56 60 40 20 0 5 14 6 12 3 4 1995 5 5.5 12 10.5 19 5 7 2005 22 6 9 2015 9 13 2025 12 12 25.5 34 25 5 9.5 14 INR billion
42
CAGR 33%
1.9
Health care Communication & transportation Housing & utilities Food, beverages & tobacco
Source: Marketing white book 2008
Gyms
Spas
35
Awareness: While increased physician awareness is driving prescriptions of nutrition supplements, penetration growth of media and diagnostic centers is helping create awareness
Physician awareness about health benefits of nutraceuticals has fuelled growth in nutrition related prescriptions at 26 % CAGR in recent years
With growing diagnostic centers, the awareness about health disorders and deficiencies is increasing
410
36% 25% 64
156
260
116
2006
2010E
2012E
36
Emergence of wellness products and services related retail outlets is also driving accessibility of nutraceuticals
Growing organized retail has emerged as a new channel for distribution of nutraceuticals
58% CAGR '000 sq. mtrs. 1,000 36% CAGR 737 400 400 86% CAGR 45 156 276% CAGR 6 85
24,300
700
12,755
2012
Existing 2007
Planned 2009
Source: ICRIER, India Retail Report
37
The Indian nutraceuticals market is dominated primarily by pharmaceuticals and FMCG companies with very few pure play nutraceutical companies
Pharmaceutical and FMCG players active in the nutraceuticals space have diversified by introducing product extensions and developing variants under existing brand names.
Direct selling
Distribution channels
FMCG dominated segments with player such as Dabur, Nestle, Amul, Pepsico and pure-play nutraceuticals players such as Amway Sports drinks Nutrition fortied foods Fortied juices Pharmaceutical dominated segments with player such as GSKCH, Emami, Ranbaxy, Elder
Grocer
15 players Consolidated
Source: Ernst and Young analysis Note: Extent of fragmentation has been derived based on the number of companies commanding greater than 80 percent market share
Largely, the market is fragmented. However, the FMCG dominated segments are relatively less fragmented as compared to the pharmaceuticals dominated segments.
38
Expansion plan Alkem Laboratories has invested over INR1 billion to create exclusive manufacturing facilities for their health foods business. Alkem Health Foods is expected to generate a turnover of over INR3-5 billion annually within a few years. The company recently acquired a USD100 million nutraceutical company named Natrol Inc in the US and is planning to launch its 700 odd products in India and other global markets. Plethico, is also setting up a INR1 billion plant in Dubai to make medicated lozenges, is targeting a turnover of over INR30 billion within five years.
Plethico
Divi's Laboratories
Divi's Laboratories has set up a INR350 million nutraceutical plant and a separate arm, Divi's Nutraceuticals. The company has already developed potential vitamin products such as Astaxanthin, Betacarotene, Canthaxanthin and Lycopene.
Mission Vivacare is investing over INR800 million in modern manufacturing facilities to launch its products globally under the brandname - Mission VivaPrime. Its prime targets are the US and Europe. Plans are on to open 150 stores by 2009, has an exclusive master franchisee tie-up with Guardian pharmacy which is investing approximately INR1 billion Operates approximately 4900 stores worldwide Plans of investing INR1.2 billion in a manufacturing unit to roll out its entire range of products in India Plans of increasing footprint through Manipal Cure and Care as well as 50 additional health and wellness centers by 2011
Source: "Drugmakers cash in on health supplement segment", 22 August 2008 Business Standard, Primary interviews
39
Even though the current nutraceuticals market is pegged at INR44 billion, there exists a large latent potential market
Nearly 70% of the undernourished population (280 million) has inadequate purchasing power to consume a calorie sufficient diet and hence is not a latent potential market. However, out of the remaining 750 million population, nearly 148 million people can be potential customers for nutraceuticals based on their affordability. It is observed that the top 3 MPCE1 groups in urban areas and the topmost MPCE1 class in rural areas (collectively referred to as "segments with affordability" from hereon) spend a significant amount (25 per cent more than average) on processed foods & beverages and would, therefore, have greater affordability to buy nutraceuticals.
Per capita monthly average expenditure on processed foods and beverages (INR)
Spend above urban average MPCE classes >2540 126 91 59 1880 2540 1380 1880 930-1380 580-930 335-580 Below food poverty line 93 24 74 31
2
271
2% 2% 3% 6% 7% 4% 0.4% 7%
Four segments with affordability make 14% of population or 148 million people
69%
Source: NSSO 2006-07, Report of the National Commission on Macroeconomics and Health 2005
Note: 1. MPCE (Monthly per capita expenditure) As per NSSO definition, for a household, this is the total consumer expenditure over all items divided by its size and expressed on a per month basis. A persons MPCE is understood as that of the household to which he or she belongs. 2. People below food poverty line have been considered to be those with monthly per capita expenditure on food less than the minimum expenditure required to consume a diet sufficient in calories and nutrients as defined in the report of the National Commission on Macroeconomics and Health, 2005
40
This latent potential market is estimated to be atleast two to four times the current market size (between INR89 billion and INR172 billion)
Current market
People going to the gymnasium and engaged in moderate to heavy work-out routines, who have an enhanced need for nutrient intake which can be met through dietary supplements like whey proteins Enhancement needs For enhanced functioning People belonging to segments with affordability and likely to have the following conditions: Adults (>20 years) likely to face vitamin deciency disorders due to signicantly lower than recommended fruit & vegetable consumption Pregnant and lactating women with an increased requirement for Condition nutrient intake like proteins, iron specic needs Other women in the age group of 15-49 years suffering from any For addressing specic conditions form of anemia Children aged between 4 to 17 years and consuming proteins needed for growth at less than RDA levels People belonging to segments with affordability who consume sufcient or excess calories (at least 90% calorie intake of recommended norm) and need products to maintain and promote a normal, healthy life
Total
Source: NSSO 2004-05, NSSO 2006-07. NNMB 2007, Ernst & Young-FICCI Wellness report, 2009, Primary interviews, Industry sources, Ernst & Young analysis
Key assumptions*
Segments with affordability (as defined earlier) form the consideration set for this analysis The following three scenarios have been considered for analysis: Scenario 1: Segments with affordability in urban areas spend 25% of their processed foods and edible oil expenditure on products that cater to foundation needs. This is in line with their current spending levels on foundation product segments. In this scenario, there is no spend assumed on foundation products by the segment with affordability in rural areas. In case of condition specific needs, 50% of the current nutrient intake gap is met through nutraceutical products, while for enhancement needs 75% of the enhanced nutrient requirement is met through nutraceuticals. Scenario 2: Segments with affordability in urban areas spend 40% of processed foods and edible oil expenditure on products to cater to foundation needs. In this scenario too, there is no spend assumed on foundation products by the segment with affordability in rural areas. In case of condition specific needs, 75% of the current nutrient intake gap is met through nutraceutical products, while for enhancement needs 90% of the enhanced nutrient requirement is met through nutraceuticals. Scenario 3: In addition to segments with affordability in urban areas spending 40%, those in rural areas spend 10% of their processed foods and edible oil expenditure on products that cater to foundation needs. In case of condition specific needs, 100% of the current nutrient intake gap is met through nutraceutical products, while for enhancement needs 100% of the enhanced nutrient requirement is met through nutraceuticals.
*Refer Annexure 1 for details Nutraceuticals Critical supplement for building a healthy India 41
However, there are critical impediments to convert this latent opportunity into a market
4
Critical impediments to growth
3
High prices of nutraceuticals
2
Inadequate resources for implementation of regulations Regulatory framework not yet implemented
42
Regulatory framework to govern the nutraceuticals market in India has not been implemented as yet
The Food Safety and Standards Act of 2006, passed by the Indian Parliament, brought into existence the Food Safety and Standards Authority of India (FSS or FSSA), which is the responsible body for framing rules and regulations to govern the nutraceuticals market. However, rules are yet to be framed and this scenario lends an environment that is not conducive for the growth of nutraceuticals. Genesis and current state of FSSA
Pre 2005 2005-2006 Post 2006
Multitude of laws and ministries governing food and food processing such as: The Prevention of Food Adulteration Act, 1954 The Fruit Products Order, 1955 The Meat Products Order, 1973 The Vegetable Oil Products (Control) Order, 1947 The Edible Oils Packaging Order Varied standards under these laws regarding manufacturing, processing, packaging etc. of foods.
A need felt for integrating all existing laws under one Group of Ministers (GOM) appointed by Government of India to propose the Integrated Food Law Food Safety and Standards Bill 2005 introduced in parliament and referred to the Standing Committee on Agriculture Recommendations made by standing committee incorporated FSS Bill passed by parliament and signed by President on 23 August 2006
While the act was passed in 2006, its implementation has not been enforced even three years down the line since rules have not been framed. Further, while there are panels that have been formed to take forward different aspects of the Act but too little has been achieved by such panels in this time period As a result, There is very limited check on the safety, efficacy and quality of the nutraceutical products. resulting in increased risk to health of consumers The claims made by many products are un-validated and left to discretion of safety officers, leading to increased chances of corruption This is also resulting in many court cases that are under disputed This is also acting as a deterrent for large foreign players planning to enter the Indian market
43
Even if regulations are established, resources available to enforce them are insufficient
There is a lack of resources in terms of Food safety officers and Central food laboratories to monitor compliance to regulations.
Monitoring reach Food processing units Current strength estimates 0.18 million food processing units 2,000 food safety officers Retail outlets Extent of inadequacy Understaffing is such that each food processing unit can be monitored only once in 2 years which is much below international norms Each retail outlet can be monitored once in only 12 years. Underlying assumptions Each food safety officer can handle 4 inspections per month of required quality
Each food safety officer can handle 25 retail outlet inspections per month
Each lab can handle 25 Each sample from retail outlets samples per day and food processing units can only be monitored once in 4 years.
Case study (Attempted optimization of existing staff from Maharashtra FDA, 1995)
The Maharashtra Foods and Drugs department was understaffed. There were 200 food inspectors and 140 drug inspectors and both fell short of required numbers for the state. Coverage was inadequate due to not just understaffing but also because there were separate cadres of drug officers and food officers with limited resource sharing. In Maharashtra FDA, a drug inspector requires a basic qualification of B.Pharm whereas a food inspector requires any B.Sc qualification. This means that if trained on the job, all drug inspectors could technically learn and perform the duties of food inspectors too. With the number of establishments under foods category increasing, there was an effort by the department in the year 1995-96 to create a unified cadre of such Food and Drugs Control Officer having degree in B. Pharm thereby increasing the number of food inspectors to 340 (70 percent increase) . However, there was resistance faced from many food and drug Inspectors on account of organization level mapping. As a result of this, no consensus could be evolved and the proposal was dropped.
Source: Primary interviews
Authorities are aware of the severe shortages in the number of food safety officers and there have been attempts to increase the strength, but despite efforts the number of such resources continues to be inadequate.
44
Prices of nutraceutical products in the Indian market are prohibitively high when compared to the conventional foods. In a highly price sensitive market such as India, this is a severe limitation on the growth in demand for nutraceuticals.
Price of conventional food/ pharmaceutical INR11 INR18 INR20 INR15 Percentage increase in price for functional food functional beverages/dietary supplement 73% for low sodium variant 139% for nutrient fortified mix for atta 350% for energy drink 233% for vitamins in the form of dietary supplements
Product Conventional and functional foods Salt Atta Conventional and functional beverages Chilled beverages Pharmaceuticals and dietary supplements Multivitamin tablets
Quantity
1 kg 1 kg 330 ml 10 tablets
Source: Ernst & Young analysis Note: Prices based on various brands available in the market
45
A survey of consumers in 13 Asia Pacific countries including India, showed that for most nutraceuticals more than 30% of the respondents felt that they do not offer any additional health benefits
Percentage of respondents who believe these products do not offer any additional health benets
42% Percentage of respondents 31% 24% 32%
This lack of belief in the benefits of nutraceuticals is further aggravated by the unsubstantiated claims made by certain products. This loss in credibility of nutraceuticals in the minds of consumers is the key limiting factor in the growth of the market.
46
Some of the key ingredients with health claims used by Indian nutraceutical players Over and above the micro and macro nutrient ingredients available in the market, there are host of ingredients used by nutraceuticals companies with diverse set of heath claims providing structure function benefits such as carotenoids, dietary fiber, fatty acids, flavonoids, isothiocyanates, phenolic acids, plant stanols/sterols and polyols. Below mentioned are few examples of ingredients used by Indian nutraceuticals players.
Used by industry categories Functional foods (Nutrition Fortified foods): e.g. omega fortified malted beverages Functional foods (Probiotic foods): e.g. probiotic yogurt
Health claim as per industry sources Omega 3 and omega 6 benefit people suffering from inflammatory and autoimmune diseases, while also reducing cholesterol, and hence, various heart risks. Lactobacillus and bifidobacterium improve intestinal microflora and aid better digestive abilities. They help in prevent diarrhea, other gastrointestinal infections, irritable bowel syndrome, and other inflammatory bowel disease Beta glucan is a soluble fibre that soaks up the cholesterol in our digestive system and help Reduce the amounts of "bad" (LDL) cholesterol in the body Reduces the risk of many kinds of cancers, cholesterol and risk of coronary heart disease, chances of osteoporosis. Known for their cholesterol lowering ability. Prevent or delay heart disease and related complications, cataracts and macular degeneration, prostate and other cancers. Retard the aging process and boost immune function and promote healing of burns, eczema, and other skin problems.
Beta glucan
Functional foods: e.g. oat enriched foods Functional Beverages: e.g. soya milk drinks Functional foods: e.g. rice barn fortified oil
Phytoestrogens
Tocopherols
Ginseng Beta-carotene
Dietary supplements: e.g. Tonics and stimulants Dietary supplements: e.g. Beta-carotene in antioxidants
Believed to cure lethargy, arthritis, impotence, senility also effective anti-aging properties Helps prevent night blindness and other eye problems, skin disorders, enhance immunity, protects against toxins and cancer formations, colds, flu, and infections. Beta-carotene is also a powerful antioxidant and helps guard against cancer and heart disease.
Source: Frost & Sullivan, Websites of Tata Tea, Pepsico, Godrej, Saffola
47
Section
III
Way forward
48
Summary
Agenda for government Lay down rules to govern quality and claims of nutraceutical products Take measures to ensure availability of adequate resources for implementation of laid out rules Encourage R&D in the field of nutrition and deploy PPP models to serve needs of the undernourished segment of population Agenda for private sector Product development: Develop customer focused products addressing specific needs of different consumer segments Product differentiation: Differentiate products by focusing on credibility building and/or lowering prices of products Product promotion: Increase awareness of the benefits of nutraceuticals through advertizing and physician education
49
Impediments
Way forward
A. Revise RDA levels to make them applicable for the Indian population's current lifestyle B. Develop rules which specify proven nutrients, permitted health claims, product approval process, standards and Good Manufacturing Practice
Take measures to ensure availability of adequate resources for implementation of laid out rules
A. Recruit and train a well-staffed cadre of food safety officers B. Scale up food control infrastructure by outsourcing testing of food samples to private laboratories
Encourage R&D in the field of nutrition and deploy PPP models to serve needs of the undernourished segment of population
A. Establish a dedicated fund focused on nutraceuticals research and support nutraceutical players by providing them with research infrastructure B. Deploy PPP models to cater to the needs of the undernourished section of the population Lack of credibility of nutraceuticals
Product promotion: Increase awareness of the benefits of nutraceuticals through mass marketing, advertising and education of physicians
50
In India, while the Food Safety and Standards Authority, created as per the Food Safety and Standards Act 2006 (FSSA), has plans to lay down rules by end of 2009 based on panel recommendations, it will be enforced state by state over an extended period of time. Here, it is of critical importance that not only are the rules made exhaustive to govern quality and claims but their implementation is also expedited.
A B
Revise RDA levels to make them applicable for Indian population's current lifestyle Develop rules which specify proven nutrients, permitted health claims, product approval process, and Good Manufacturing Practice
i ii iii
Recognize list of nutritional ingredients with proven health benefits Define the list of permitted health claims and specify quantity of ingredients required to make those claims Setup a process for introduction of new nutraceutical products and define the nature and range of evidence required to substantiate product claims
400 300 200 100 0 2 1993 69 1995 6.2 80 50 5 100 50 1998 1999 9.8 153 150
15 300 192
15 10 5 0
1997
2000
51
1.A. Revise RDA levels to make them applicable for Indian population's current lifestyle
India is currently using the RDA (Recommended Dietary Allowance) system with norms last defined 20 years ago (year 1989) by ICMR (Indian council of Medical Research). These norms are outdated and do not reflect the lifestyle changes as well as the considerable nutritional research accumulated in this period. The need for urgently revising these norms has also been identified in the 10th Five Year Plan acknowledging that the existing RDA norms are overstating nutrition needs and should undergo revision. At the same time, countries such as the US, Canada, Australia and New Zealand have replaced the RDA system with more advanced systems (Dietary Reference Intakes in the US and Canada, Nutrient Reference Values in Australia and New Zealand). These advanced systems have noteworthy merits for India to learn from but the time taken to adopt them would also be significant, and is a longer term measure that is needed.
2 1
Introduce a more appropriate system to plan diets for population groups and individuals based on concepts such as Dietary Reference Intake (DRI)* RDA is an "average level" of nutrient intake which prevents the development of deficiency disorder. They are meant to assess and plan dietary adequacy of population groups. But they end up being used to plan diets of individuals which can be misleading. There are advanced concepts such as the Dietary Reference Intake (DRI) framework which are used in some developed countries. DRI provides the nutrient norms that helps prevent the development of risk factors for chronic diseases related to inadequate intake for that nutrient. DRI norm is an umbrella which includes RDA level, Tolerable Upper Intake level, Adequate intake level and Estimated Average Requirement level. Each one of these levels have specific application when it comes to establishing the recommended intake at an individual or group level.
Revise RDA levels to factor in effects of changed lifestyles and new research in the field of nutrition Revision of RDA levels should be taken up as an immediate activity: As per the 10th Five Year Plan, the reference (male and female) weights used to calculate RDA in 1989 for Indians were not accurate. They were higher than the average weight of Indian men and women Also, since then the trends of physical activity and dietary habits of Indians has changed considerably Considerable nutritional research has also accumulated in the last 20 years which would change some base assumptions of calculating RDA
Need
Energy requirements for average Indian male is nearly 13% lower across activity categories compared recommended levels as per RDA of 1989 Energy requirements of average Indian male
Comparison of RDA and DRI levels in USA for some nutrients shows considerable changes in recommended levels of nutrients between 1989 and 1997 Vitamin A levels for women 19 to 50 years
12.5% 3000
Case
13% 2425 2115
Sedentary
1997 DRI
Recommended as per 1989 RDA Requirements as per average Indian male weight
Source: 10 Five Year Plan, planning commission
th
52
1.B.
Develop rules which specify proven nutrients, permitted health claims, product approval process, standards and Good Manufacturing Practice
Rules with regards to proven nutrients, permitted health claims, product approvals, standards and GMP need to be defined exhaustively.
i ii iii
Recognize list of nutritional ingredients with proven health benefits Define the list of permitted health claims and specify quantity of ingredients required to make those claims Setup a process for introduction of new nutraceutical products and define the nature and range of evidence required to substantiate product claims
Scientific panels have been set-up within the FSSA for defining rules to govern nutraceuticals market & label claims. Apart from Codex guidelines some of the practices that can be referred to while framing these rules are illustrated in the table below:
Key clauses for maintaining quality standards Is a defined list of proven nutraceutical ingredients and their functions available? Can a new product having ingredients which are already marketed be launched without approval/license? Can a new product having a "new dietary ingredient" not previously marketed be launched without approval/license? Is Good Manufacturing Practices (GMP) in place for manufacturing of nutraceuticals? Management of claims on label Is a claim specifying the beneficial effect on structure or function of the body permitted? To be decided The act only specifies that claims should not be false or misleading. Rules to govern claims are yet to be laid down. To be decided The act only specifies that claims should not be false or misleading. Rules to govern claims are yet to be laid down. To be decided Rules of the act not laid down yet, hence no list currently available To be decided Regulations which specify the approval process have not been framed yet To be decided Regulations which specify the approval process have not been framed yet
(Each new product needs FOSHU approval) (Pre-marketing notification along with evidence of safety has to be submitted) (Each new product needs FOSHU approval) (Each new product needs approval and product license) (Each new product needs approval and product license)
To be decided Rules specifying GMP/standards would be part of the rules of the act when they are laid down
(The claim and the supporting evidence is tested and validated in the approval process)
(The claim and the supporting evidence is tested and validated in the approval process)
(The claim and the supporting evidence is tested and validated in the approval process)
(The claim and the supporting evidence is tested and validated in the approval process)
Enforcement and monitoring of regulations Is monitoring done through inspections and random sampling of products in market? Is a record of adverse events required to be maintained? To be decided Act has not been implemented yet.
To be decided Rules yet to be laid down in the act with regards to manufacturer maintaining a record of all adverse events
Source: US Food & Drug Administration website; "Health Claim Evidence Requirements in Japan,(Yamada et al); Health Canada Natural Health Products Directorate website; Food Safety and Standards Act of India, 2006
54
Foods for people with high cholesterol/ triglyceride levels and body fat
Source: The World Bank - Agricultural and Rural Development Discussion Paper 30 "Health Enhancing Foods" *Refer Annexure 3 for details
(Lutein, lycopene)
55
ii
Define the list of permitted health claims and specify dosages of ingredients required to make those claims
What needs to be done?
The scientific panel on management of claims within the FSSA needs to frame a policy on the nature of claims that would be acceptable The level of regulatory control needs to be in line with the nature of claim while a low level of control is sufficient for nutrition content claims, a high level of control is required for risk reduction claims ( types of claims and their definitions are provided below) For nutrition content claims and health claims, rules could specify the ingredient content limits. Further, for health claims a list of acceptable claims needs to be identified based on scientific evidence
Claims made on the labels of nutraceutical products are generally classified into three types and the level of regulatory control exercised on each type could vary as shown: Nutrition claims Health claims
1
Types
Nutrition content claims Nutrition claims state, suggest or imply that a food has particular nutritional properties. Foods which claim to be sources of Energy Protein Carbohydrates Vitamins Minerals Source of calcium
Structure/function claims Structure-function claims describe A nutritional ingredients effect on a structure or physiological function in the human body, or Its support of an anatomical, physiological, or mental function Non-specific claims of overall health are also included "Maintains healthy gums" "A factor in the maintenance of good health" Medium No pre-approval is required Pre-launch notification to FDA is required along with evidence of claim Along with the claim a disclaimer is required on label mentioning that the claim is not FDA approved
Risk reduction claims Risk reduction claims describe the relationship between using a medicinal ingredient and reducing the risk of developing a specific disease or abnormal physiological state
Definition
Examples
Low No pre-approval of FDA is required No evidence is required to be submitted Nutrients and quantities are required to be mentioned on label
High Claim has to be for one of the ingredients in the preapproved list of proven and qualified health claims The quantities of nutrients required for the claim to be made are also required to be specified
Source: Codex guidelines for use of nutritional and health claims; US FDA website *Refer Annexure 4 for details
56
iii
The process for introducing a new nutraceutical whether approval based or notification based should be clearly specified as part of the rules and regulations of FSSA. For an approval based system, the authorities responsible for processing the application and granting approval should be identified and trained for standardization in implementation. For a notification based system, a channel should be set-up to hear, record and process consumer grievances or adverse event reports In the Indian context, opting for an approval based process may lead to a regulatory bottleneck and delays. On the other hand, a large proportion of the Indian consumers may not have adequate awareness or education levels because of which a notification based process might lead to compromising consumer safety. Hence a hybrid of the two processes needs to be conceived and implemented The nature and range of evidence required to substantiate a particular health claim needs to be defined clearly.
Approval/license based High Manufacturer applies for approval to the recognized authority (local governments, FDA) The application by manufacturer includes the evidence to substantiate product claims
Notification based Low For a new product with ingredients which are already marketed, no approval is required. Manufacturer notifies the FDA prior to launch. If there is a health claim associated with the product, then the notification includes evidence to substantiate claims The responsibility to ensure safety and efficacy of the nutraceutical product lies with the manufacturer Reduced burden on the FDA with lesser resources needed to control the market (labs & inspectors) Lesser time to market for new products Reduced scope for corruption which might be prevalent in strictly controlled environment where licenses are granted
Key features
The responsibility to ensure the safety and efficacy of the nutraceutical product in the market lies with the authority granting approval
Consumer safety can be ensured and misleading claims can be barred centrally
Advantages
Reduced effort on monitoring, through sampling and testing of products from the market Reduced reliance on consumer reporting of adverse events
Japan*: All new products have to get approval to be sold as a FOSHU product The application for a product is required to include documentation regarding:
USA: Products with ingredients which have already been marketed do not need approval. A notification has to be given with evidence to support health claims For new ingredients, the pre-marketing notification has to be 75 days prior to launch in which period the FDA can analyze evidence and raise concerns with the manufacturer The manufacturer is required to maintain a record of all adverse events reported by consumers. Monitoring Monitoring is done based on exceptions
Cases
Its effectiveness based on scientific evidence including clinical studies Its safety based on historical consumption pattern Analytical method for determination of the functional component Samples of the product are also tested in a public food laboratory before approval is granted
Source: Health Claim Evidence Requirements in Japan,(Yamada et al); US FDA website *Refer Annexure 5 for details
58
2.
Take measures to ensure availability of adequate resources for implementation and enforcement of regulations
Current challenges What needs to be done?
Formalize mechanism to capture data on exact numbers Sharing of data on infrastructure and its electronic storage is critical to manage and track the inspection of all food processing units, retail outlets, stockists by food safety officers. Coordination and implementation across key stakeholders across public bodies such as local governments and state level FDAs is required and periodic status reports need to be made possible
Insufficient strength of Food Safety Officers (FSO) to inspect and evaluate food processing units, stockists and retailers
Evaluate gaps in number of food safety officers and recruit to fill those gaps State Food and Drug Administrations need to assess gap in required and available food safety officers and recruit to scale up and meet the required number
Authorize an external agency to evaluate and grant approval to products An external agency could be appointed to evaluate nutraceutical products for safety and efficacy based on the standards and GMP framed as a part of regulations
Inspection of nutraceutical products would require more specialized knowledge and processes
Approvals by this agency would be in the form of a mark on the product which would help build credibility for tested and proven products
Train Food Safety Officers to improve quality of inspection of facilities Food safety officers should be trained in a phase-wise manner to inspect facilities for manufacture, packaging, distribution and sale of nutraceuticals
Develop a network of central food testing laboratories Infrastructure needs be scaled up to have at least one central laboratory in each state as role model All central laboratories need to to follow Good Laboratory Practices or get accreditation Appoint private laboratories and outsource testing of food samples Evaluate competence of private laboratories Authorize competent laboratories to conduct tests on food samples for FDA
Source: Primary interviews; Ministry of Food Processing industries website; Industry sources
59
3.
Encourage R&D in nutritional food sector and deploy PPP models to serve needs of the undernourished segment of population
Current challenges
Establish a dedicated fund for nutraceuticals research Encourage research in the field of nutraceuticals by funding relevant research and development in nutraceuticals Provide R&D infrastructure support to nutraceutical players for conducting research
Allow use of public research facilities and food laboratories to nutraceutical companies to give an impetus to R&D Collaboration between industry and academia Encourage collaborations between education and research institutions and the industry so that there is a vigorous exchange of ideas. Set up a central nutraceutical technology and research center. This center can be a forum where eminent people from R&D institutions, medical institutions, nutraceutical manufacturers, regulators, researchers can interact and exchange ideas to fuel growth of the industry Public-private partnerships
Imbalance of nutritional ingredients in the food provided to the undernourished through government schemes
Deploy PPP models in the government schemes to supply food to the undernourished segment of the population The private partner could provide fortification of the food so that required nutrients are delivered. They can also provide surveillance and logistics management services to ensure the responsible supply of unadulterated micronutrients.
It is a part of the government agenda to meet nutritional deficiencies in the undernourished segment of the Indian population
Major goals of "National Nutrition Plan" to be met by 2012
Reduce the prevalence of underweight condition in children under five years to 20% Eradicate the prevalence of severe under-nutrition in children under five years Reduce prevalence of anaemia in high risk groups (infants, pre-school children, adolescent girls, pregnant and lactating women) to 25 % Eliminate vitamin A deficiency in children under five years as a public health problem and reduce sub-clinical deficiency of vitamin A in children by 50 % Reduce prevalence of Iodine deficiency disorders to less than 5 %
Source: 11th Five Year Plan, Working group on integrating nutrition with health
60
These goals are to be achieved through multiple health and nutrition interventions planned by the government
Some nutrition interventions undertaken by different sectors of the government
Integrated Child Development Scheme (ICDS) Nutrition Program for Adolescent Girls (NPAG) Iron and Folic Acid supplementation of pregnant women Vitamin A supplementation of children of 9 to 36 months age group National Iodine Deficiency Disorders Control Programme Mid day meal for primary school children
Source: 11th Five Year Plan, Working group on integrating nutrition with health
However there are gaps in the implementation of these existing nutrition interventions which can be filled by ensuring participation of the private sector through Public Private Partnerships
Some Issues Role of private sector
Partner with the government in supplementation and fortification of the food dispensed through government initiatives
Provide surveillance and logistics management services to ensure the responsible supply of unadulterated micronutrients
Source: India Micronutrient National Investment Plan 2007-2011 , Micronutrient India ; Network for Social Accountability website ; Ernst & Young analysis
1 Product development Develop consumer focused products and product variants for different target segments
2 A. Build credibility Product differentiation Ensure publication of efcacy studies and research results in scientic/medical journals B. Lower prices Improve processes/technology to reduce cost of production
3 Educate physicians about published research on nutrition Formulate health claims as per published research and approvals Use general media to communicate benets & differentiation
Product promotion
Physician awareness
Public awareness
Health
62
1.
Product development: develop consumer focused products for different target segments
What needs to be done?
Develop consumer focused products for different target segments Enable easier diagnosis of nutrient deficiency
Understand nutrition needs of different segments of consumers Develop relevant nutraceutical products targeted at different consumer segments with regard to their preferences and taste Considering a large proportion of the population is not aware of their specific nutritional deficiencies, there is also a potential market for a nutrient deficiency diagnostic test/kit
Leverage traditional Indian knowledge in herbs and botanicals to develop new nutraceuticals
Convert the nutritional properties of herbs and botanicals as per knowledge derived from traditional Indian sources into products for consumer
Case study 1 Identifying customer needs and positioning products to meet these needs
Calcium Sandoz switched to the OTC route from the ethical pharmaceutical route in 2000 Since then, Novartis has continuously identified needs of different target segments of consumers and positioned variants for each segment.
Consistent growth in sales (INR million) of the Calcium Sandoz brand after introduction of multiple variants to cater to specic user needs 320 CAGR 15%
120
Launch of Calcium Sandoz Soft Chew in various avors targeted at children in their semi-teens 2006 2007 2008
2001
2002
2003
2004
2005
Case study 2 Collaboration with the government to innovate nutraceuticals from traditional medicine knowledge
Avesthagen and Indian Council of Medical Research (ICMR) A memorandum of understanding was signed between Avesthagen Limited, a knowledge based Lifesciences Company and the Indian Council of Medical Research (ICMR) for the formulation, coordination and promotion of biomedical research for three years. As per the agreement both the parties will be exploring possibilities to innovate nutraceutical development from traditional and folk medicine by knowledge sharing. The agreement will open new avenues for research on traditional Indian medicinal plants and their nutritional properties.
Source: Express Pharma, 115 September 2008
2.
In the absence of intellectual property protection, product differentiation in case of nutraceutical products can be achieved either through building credibility of the brand/company or through prices lower than existing players in the market
Way forward
Adhere to all rules and regulations laid down to govern manufacture, distribution and sale of nutraceutical products Follow standards, GMP, claim regulations and approval process for nutraceutical products
Get results of efficacy studies published in medical journals as proof of efficacy and safety of the product Obtain approval of reputed and trustworthy external institutions for the product and its claim
Lower prices of nutraceutical products to target a larger consumer base instead of a niche segment Focus on cost reduction in manufacturing to help improve affordability of products
Case study 1 Reputed external institution in USA granting approvals to nutraceutical products
The USP (US Pharmacopeia) Dietary Supplement Verification Program in USA is a voluntary testing and auditing program. This program validates the quality, purity, and potency of dietary supplement finished products through: Comprehensive laboratory testing against standards A thorough manufacturing and quality control document review An on-site manufacturing facility audit Random off-the-shelf testing USP's expertise in setting standards of quality for medications for 200 years helps in lending credibility to products which carry its approval
Source: US Pharmacopeia Dietary Supplement Verification Program website
Case study 2 Efficacy studies for a product published and external institutional approval taken
A chilled fruit juice product "Sirco" from Provexis launched in the UK contains the patented Fruitflow bioactive food ingredient that reduces blood platelet aggregation, a significant contributing factor to thrombosis, which can cause heart attack or stroke. In May 2006, Provexis, announced a scientific endorsement for Sirco; two scientific papers, which detailed the clinical efficacy of Sirco, were published by the American Journal of Clinical Nutrition (AJCN), an internationally recognized journal in the nutrition field. This followed the 2005 announcement of a three year collaboration with registered heart health charity, Heart UK, which allowed Provexis formal approval for its Sirco product, allowing Sirco to wear the Heart UK logo on its packaging. Such endorsements on the packaging of the product from renowned institutions offer credibility to claims that the product is good for the heart.
Source: "Functional Food and Drink Consumption Trends"-Datamonitor
3.
Product promotion: increase awareness of the benefits of nutraceuticals through mass marketing, advertising and education of physicians
Get the relevant research published in research and medical journals so that it reaches the physicians as a part of their CME(Continuous Medical Education)
There is a need to educate the consumers about the relation between a healthy life and a diet rich in nutrition
Based on the profile of customers identify various media channels of communication such as TV, newspapers, magazines, direct selling etc. Create the right content for communication which addresses customer needs or creates awareness to activate latent needs Selection of the right strategy need not be cost/investment heavy
Case "Revital" is Ranbaxys adult health supplement which transitioned from prescription to OTC in 2002.
Ranbaxy used a well thought out television creative to target the consumer directly through advertizing. "Revital" was positioned to fit into the users hectic lifestyle empowering them with energy strength & mental sharpness, enabling them to enjoy life to the fullest, hence making them live the brand punch line of Jiyo Jee Bhar Ke The advertising was spread over three phases: In the first phase the commercials sought to demonstrate the pre-use scenario and post-use benefits.
40
2002
2007
Source: Revitalizing the brand, Express Pharma 31 march 2006; Industry sources
The second phase showed how a consumer of "Revital" was able to make the most of his life which his colleagues and friends are unable to do. The third phase is in the form of testimonials by regular users of "Revital"
Annexure
Annexure 1: Estimation of potential market
Market size estimation for foundation needs: Target market of people belonging to segments with affordability and consuming at least sufficient calories but needing products to maintain and promote a normal, healthy life
Parameter
Assumption
Population belonging to top 3 MPCE classes in urban areas and topmost MPCE class in rural areas The number of actual consumers will vary with each scenario with growing awareness
The population consuming at least sufficient food (>90% of norm of 2700 kcal/day), would have the propensity to further buy nutraceuticals to maintain their general well-being. The proportion of such population would vary with MPCE class
NSSO 2004-05
Amount willing to spend on such products would be in proportion to spend on food categories like processed food and beverages This spend would increase with increasing MPCE and would vary with each scenario
Source
NSSO 2006-07
66
Market size estimation for condition-specific needs (1/4): Target market of adults (>20 years) likely to face vitamin and mineral deficiency disorders due to significantly lower than recommended fruit & vegetable consumption
Parameter
Assumption
Population belonging to top 3 MPCE classes in urban areas and topmost MPCE class in rural areas
The overall age wise break-up of population for urban and rural areas was equated to the respective MPCE classes
Assuming that the households in which fruit and vegetable consumption is less than average (which is still lower than ICMR norms), will be facing deficiencies in vitamins The proportion of such households would vary with each MPCE class
The gap is arrived at for the most extensively tracked vitamins The extent of this gap varies with MPCE classes Further, the tendency to address this gap with nutraceuticals will vary with each scenario
NNMB 2007
Source
NSSO 2006-07
NSSO 2004-05
NSSO 2004-05
Ernst & Young analysis Note: Prices based on various brands available in market
67
Market size estimation for condition-specific needs (2/4): Target market of pregnant and lactating women with an increased requirement for nutrient intake like proteins, iron
Parameter
Percentage pregnant and lactating women in the age group of 15-49 years
Assumption
Women belonging to top 3 MPCE classes in urban areas and topmost MPCE class in rural areas
The overall proportion of women in the age 15-49 years for urban and rural areas was assumed to be applicable for the respective MPCE classes Based on the birth rate figures, number of pregnant and lactating women were arrived at
The gap is arrived at for the key representative nutrients proteins and iron The extent of this gap varies with MPCE classes Further, the tendency to address this gap with nutraceuticals will vary with each scenario
Representative price of the most commonly used protein and iron supplements is considered
Source
NSSO 2006-07
NSSO 2004-05
NNMB 2007
Ernst & Young analysis Note: Prices based on various brands available in market
Potential market for nutrients for pregnant and lactating women (INR billion)
Scenario 1 20.1 Scenario 2 30.2 Scenario 3 40.3
68
Market size estimation for condition-specific needs (3/4): Target market of other women in the age group of 15-49 years suffering from any form of anemiao
Parameter
Assumption
Women belonging to top 3 MPCE classes in urban areas and topmost MPCE class in rural areas
The overall proportion of women in the age 15-49 years for urban and rural areas was assumed to be applicable for the respective MPCE classes The number of pregnant and lactating women is subtracted from the total figure
Women suffering from any form of anemia and belonging to this age group would have maximum impact due to loss of iron through blood during menstruation Proportion of such women belonging to the high income groups was considered
The extent of this gap varies with MPCE classes Further, the tendency to address this gap with nutraceuticals will vary with each scenario
Source
NSSO 2006-07
NSSO 2004-05
NFHS 3, 2005-06
NNMB 2007
Ernst & Young analysis Note: Prices based on various brands available in market
69
Market size estimation for condition-specific needs (4/4): Target market of children aged between 4 to 17 years and consuming less than RDA proteins needed for growth
Parameter
Assumption
Population belonging to top 3 MPCE classes in urban areas and topmost MPCE class in rural areas
The overall proportion of children in this age group in urban and rural areas was assumed to be applicable for the respective MPCE classes
Households in which overall protein consumption is less than RDA limits, were considered The proportion of such households would vary with each MPCE class
The extent of this gap varies with MPCE classes Further, the tendency to address this gap with nutraceuticals will vary with each scenario
Source
NSSO 2006-07
NSSO 2004-05
NNMB 2007
Ernst & Young analysis Note: Prices based on various brands available in market
70
Market size estimation for enhancement needs: Target market of people going to the gym and engaged in moderate to heavy work-out routines, who have an enhanced need for nutrient intake
Parameter
Based on annual size of gym market and average subscription per user Assumption
Typically a proportion of these gym goers who are engaged in moderate to heavy work-out would be needing enhanced protein nutrition
Protein requirement of such people is usually 20% higher than RDA for an average sedentary male However, the tendency to address this additional requirement with nutraceuticals will vary with each scenario
Source
Ernst & Young analysis Note: Prices based on various brands available in market
71
Annexure-2
An understanding of Dietary Reference Intakes (DRI) Reference values known in the United States as Recommended Dietary Allowances (RDAs) and in Canada as Recommended Nutrient Intakes (RNIs) were used through the 1990s. They were established primarily to set nutrition and health policy.
Need
In 1994, in response to significant changes in the nutrition field as well as the recognition that for many nutrients the single RDA values did not meet the expanding needs for nutrient reference values, the IOM began an initiative to develop a new, broader set of values known as the DRIs. The U.S. and Canadian governments supported this initiative In 1997, the first DRI report was released. In the subsequent years, RDA/AI levels for other nutrients were described
Dietary Reference Intakes Definitions Estimated Average Requirement (EAR): Reflects the estimated median requirement and is particularly appropriate for applications related to planning and assessing intakes for groups of persons.
DRIs
Recommended Dietary Allowance (RDA): Derived from the EAR and covers the requirements for 97% of the population. Tolerable Upper Intake Level (UL): Highest average intake that is likely to pose no risk. Adequate Intake (AI): Used when an EAR/RDA cannot be developed; average intake level based on observed or experimental intakes.
DRI has significant advantages over older RDAs. The new DRIs 1
Include upper levels of intake, where appropriate. Upper levels were not defined in the older RDAs prior to 1997. This provided a safe upper limit for nutrient intake.
Advantages
Specifically highlight concepts of probability and risk for defining reference values. The EARs use the median values to calculate the RDA levels taking into account the distribution of dietary requirements for each nutrient (where possible). This accurate calculation of the DRIs was useful in their application to determine adequacy of diet at an individual level. The older RDAs used the average values determined from a group of the population and extrapolated to determine RDA levels... Incorporate chronic disease endpoints within the array of endpoints that may serve to establish adequate intake or upper intake levels where possible. The older RDAs used appearance of signs or symptoms of deficiency disorders as endpoints
Source: Dietary reference intakes for calcium, phosphorus, magnesium, vitamin D, and fluoride/Standing Committee on the Scientific, Evaluation of Dietary Reference Intakes, Food and Nutrition Board, Institute of Medicine.USA; The Development of DRIs 1994-2004: Lessons Learned and New Challenges: Workshop Summary- Food and Nutrition Board, Institute of Medicine, National Academy of Sciences, USA
72
Annexure-3
Case studies: Approved functions and functional ingredients
Japan:
In the mid 1980s Japan was faced with a crisis having an ageing population with its increasing health problems and the expected increases in health care costs as a result. This pushed government-initiated research to investigate, in-depth, the role foods can play in reversing and preventing the prevalent chronic health conditions. "Foods for Special Health Use" (FOSHU) regulations were framed and implemented by the Ministry of Health, Labor and Welfare (MHLW) in 1991, which recognized various health conditions for which a list of preventive foods was made. FOSHU functions and functional food components FOSHU function Foods for gastrointestinal health Approved products (number) Main functional ingredients 254 Oligosaccharides, Lactobacillus, Bifidobacterium, Psyllium husk, indigestible dextrin, wheat bran, low molecular sodium, alginate, partially hydrolyzed guar gum Soy protein, chitosan, low molecular sodium alginate, peptides, diacylclycerol, plant sterol/stanol (esters), green tea catechin, middle chain fatty acid, degradation products of globin protein, Psyllium husk indigestible dextrin, L-arabinose, wheat albumin G A B A, peptides Xylitol, polyols, tea polyphenols, CPP-ACP Soy isoflavone Heme iron
Foods for people with high cholesterol/ triglyceride level and body fat
117
Foods for those with high blood glucose Foods for those with high blood pressure Foods for dental health Foods for bone health Foods for those prone to anemia
71 64 34 26 3
Source: The World Bank - Agricultural and Rural Development Discussion Paper 30 "Health Enhancing Foods"; "Health Claim Evidence Requirements in Japan", Yamada et al
In April 2001, a new category was introduced by MHLW "Foods with Nutrition Function Claims" (FNFC) under which 12 vitamins including vitamin A; thiamin; riboflavin; vitamins B-6, B-12, C, E, D; biotin, pantothenic acid, folic acid, niacin as well as minerals calcium, iron, zinc, magnesium and copper have been standardized
Brazil:
Functional food regulations were introduced in Brazil in 1999, and since then over 200 products have been approved with 14 different functional property claims. Food Components and related approved functions Approved functions Foods for maintenance of healthy blood triglyceride levels Foods for protection against cellular damage from free radicals Foods for intestinal function Foods for balanced intestinal flore Foods to reduce absorption of fats/ cholesterol Foods for reduction of cholesterol Functional ingredients Omega 3 Lutein, Lycopene Dietary fiber, Lactulose Fructo-oligosaccharides, inulin, Beta-glucan, Psyllium, Quitosan, Plant sterols Soy protein
Source: The World Bank - Agricultural and Rural Development Discussion Paper 30 "Health Enhancing Foods"
73
Annexure-4
Case study: Regulations governing nutrition and health claims
USA:
Claims on nutraceutical product labels are governed by DSHEA and NLEA in the USA
No pre-approval required Guidelines provided for content level and evidence required
No pre-approval required Pre-marketing notification to the FDA 30 days prior to marketing the product Manufacturer responsible for having sufficient evidence to back-up the claims made Disclaimer on the label stating that the claim is "not approved by FDA" and "the product does not prevent, cure, treat any specific disease or condition"
Pre-approved list of permitted risk reduction claims for certain ingredients is available If the product contains one of these ingredients in specified quantities, the related claim can be made Pre-approved list of permitted risk reduction claims: Calcium and Osteoporosis Dietary Lipids (Fat) and Cancer Dietary Saturated Fat and Cholesterol and Risk of Coronary Heart Disease Dietary Non-cariogenic Carbohydrate Sweeteners and Dental Caries Fiber-containing Grain Products, Fruits and Vegetables and Cancer Folic Acid and Neural Tube Defects Fruits and Vegetables and Cancer Fruits, Vegetables and Grain Products that contain Fiber, particularly Soluble Fiber, and Risk of Coronary Heart Disease Sodium and Hypertension Soluble Fiber from Certain Foods and Risk of Coronary Heart Disease Soy Protein and Risk of Coronary Heart Disease Stanols and/or Sterols and Risk of Coronary Heart Disease
Source: US Food & Drug Administration website
74
Annexure-5
Case studies: Regulatory process for launch of a new nutraceutical product
Japan:
As per FOSHU, all manufacturers that seek approval for their products need to go through the approval process before they can market their product. Process of FOSHU approval
Manufacturer submits application to the Office of Health Policy on Newly Developed Foods (The Office) under the MHLW The application for a product should include documentation regarding: Its effectiveness based on scientific evidence including clinical studies Its safety based on historical consumption pattern Analytical method for determination of the functional component
Manufacturer 3. Submit samples & get analysis National Inst.for health & nutrition
4. Submit analysis
Expert committees evaluate the application for efficacy Opinions of the Food Safety Commission is taken to evaluate safety
If application is appropriate, the MHLW notifies the manufacturer to send samples for testing to the National Institution of Health and Nutrition After validation and testing of samples is done, the product is granted FOSHU approval
75
Acknowledgements
Ajit Singh
President Health Foods and Dietary Supplements Association
Priya Parab
Proprietor Vihaan Naturals
Dr. R.B.Smarta
Managing Director Interlink Marketing Consultancy Pvt. Ltd.
Arun Kelkar
Managing Director Hexagon Nutrition Pvt. Ltd.
R. D.Joshi
(Former Secretary General OPPI) Director Business Processes Interlink Marketing Consultancy Pvt. Ltd.
Ranjit Puranik
Chief Executive Officer Shri Dhootpapeshwar Ltd.
Chanchal K. Chadha
Regional Vice President International Sales and Marketing NBTY Inc.
Deepali Shukla
Head - Marketing Amway India
Dr.S.K.Sharma
Manager - Marketing Zandu Pharmaceuticals
S.W.Deshpande
Advocate Former Joint Commissioner FDA- Maharashtra
Himanshoo Nayak
General Manager Business development Elder Pharmaceuticals
Sanjay Singh
Technical manager Plethico Pharmaceuticals Ltd.
Shrihari Shidaye
Vice President - Sales, Marketing and Business development Piramal Healthcare Ltd.
Dr. U.Y.Rege
Proprietor Mukta Technical Consultancy Services
Pradeep Patil
G.M - Marketing Zandu Pharmaceuticals.
Vikram Trivedi
Senior Research Manager R&D Zandu Pharmaceuticals
76
Glossary of terms
Glossary of terms (1/3)
Term AI AJCN Antioxidants BCC B Pharm B Sc Chronic Illness/disorder CAGR CCP-ACP CME CVD DALY Adequate Intake American Journal of Clinical Nutrition A compound that helps to protect cells against damage by free radicals eg: flavonoids Business Communications Company Bachelor of Pharmacy Bachelor of Science Illness/disorder that is long term or permanent and requires prolonged treatment Compounded Annual Growth Rate. The standard formula is: (last number/first number)^(1/periods)-1 Casein Phosphopeptide-Amorphous Calcium Phosphate Continuous Medical Education Cardio Vascular Disease Disability-Adjusted Life Year.DALY is a measure of overall disease burden. It was originally developed by the World Health Organization. DALYs are calculated by taking the sum of these two components. In a formula: DALY = YLL (Years of Life Lost) + YLD (Years Lived with Disability). Dietary Reference Intake.DRI is a system of nutrition recommendations from the Institute of Medicine (IOM) of the US National Academy of Sciences. The DRI system is used by both the United States and Canada and is intended for the general public and health professionals. Dietary Supplement Health and Education Act Under the DSHEA, the dietary supplement manufacturer is responsible for ensuring that a dietary supplement is safe before it is marketed. FDA is responsible for taking action against any unsafe dietary supplement product after it reaches the market. Estimated Average Requirement Food and Drug Administration Federation of Indian Chambers of Commerce and Industry Fast Moving Consumer Goods Foods with nutrients added in addition to the levels that were originally found eg: edible oils fortified with vitamins A and D Foods with Nutrition Functional Claims Foods for Special Health Use Food Safety Officers Food Safety and Standards Explanation
DRI
DSHEA
EAR FDA FICCI FMCG Fortified foods FNFC FOSHU FSO FSS
77
Glossary of terms
Glossary of terms (2/3)
Term FSSA GABA GDP Food Safety and Standards Act Gamma-Aminobutyric acid Gross Domestic ProductGDP is a basic measure of a country's economic performance and is the market value of all final goods and services made within the borders of a nation in a year .It calculated as: GDP = private consumption + gross investment + government spending + (exports imports) Good manufacturing practice Group of Ministers Glaxo SmithKline Consumer Healthcare Integrated Child Development Scheme Indian Council of Medical Research Indian Council for Research and International Economic Relations Indian rupee Intelligence Quotient Kilo calories ( 1 Kilo Cal = 1000 calories) Low density lipoprotein Number of maternal deaths related to childbearing divided by the number of live births Million per annum Monthly Per Capita Expenditure National Accreditation Board for Testing and Calibration Laboratories National Council of Applied Economic Research National Family Health Survey Vitamin B3- important for normal function of gastrointestinal and nervous systems, deficiency of which leads to pellagra Nutrition Labeling and Education Act National Nutrition Monitoring Bureau National Sample Survey Organization Over The Counter Food containing live micro-organisms which on consumption in adequate amounts, confer a health benefit to the consumer eg: Probiotic ice cream Public Private Partnerships Recommended Dietary Allowance Explanation
GMP GOM GSK CH ICDS ICMR ICRIER INR IQ KCal LDL Maternal Mortality Rate MPA MPCE NABL NCAER NFHS Niacin NLEA NNMB NSSO OTC Probiotic food PPP RDA
78
Glossary of terms
Glossary of terms (3/3)
Term RNI SD Thiamin UL USD USP WHO Recommended Nutrient Intakes Standard Deviation Vitamin B1 which helps to maintain appetite and growth, deficiency of which causes beri beri Tolerable Upper Intake Level US dollar United States Pharmacopeia World Health Organization Explanation
79
About FICCI
Set up in 1927, FICCI is the largest and oldest apex business organization of Indian business. Its history is very closely interwoven with the freedom movement. FICCI inspired economic nationalism as a political tool to fight against discriminatory economic policies. FICCIs commitment is now directed at changing the economic landscape of India, through reforms that expand the space for private sector and public private partnerships. FICCI is the rallying point for free enterprises in India. It has empowered Indian businesses, in the changing times, to shore up their competitiveness and enhance their global reach. FICCI maintains the lead as the proactive business solution provider through research, interactions at the highest political level and global networking. In the knowledge-driven globalized economy, FICCI stands for quality, competitiveness, transparency, accountability and businessgovernment-civil society partnership to spread ethics-based business practices and to enhance the quality of life of the common people. FICCI- Western Regional Council is the western regional arm of the Federation of Indian Chambers of Commerce & Industry, which has 14 domestic and 7 overseas offices. In addition to supporting FICCI, New Delhi, FICCI-WRC organizes its own conferences, seminars, workshops and networks with visiting delegations from several developing countries. FICCI WRC actively provides sectoral services in brand protection, boating, business matching, design, gems & jewellery, nutraceuticals, progressive Maharashtra, textiles, technical textiles and wellness.
For more details contact: Dr. Vaijayanti Pandit/Ms. Amita Kardile (+91 9890069558)
Director FICCI Western Regional Council Plot no. 33B Krishnamai Building Sir Pochkhanwala Road, Worli Mumbai 400 030 Telephone: +91 022-24968000 Fax: +91 022-24966631/32 E-mail: drvpandit@ficci.com/amitak@ficci.com
Head Office
Federation of Indian Chambers of Commerce & Industry Federation House Tansen Marg New Delhi 110 001 Website: www.ficci.com
80
Notes
81
Mumbai 6th floor & 18th floor, Express Towers Nariman Point Mumbai - 400 021 Tel: + 91 22 6657 9200 (6th floor) Fax: + 91 22 2287 6401 Tel: + 91 22 6665 5000 (18th floor) Fax: + 91 22 2282 6000 Jolly Makers Chambers II 15th floor, Nariman Point Mumbai - 400 021 Tel: + 91 22 6749 8000 Fax: + 91 22 6749 8200 Jalan Mill Compound 95 Ganpatrao Kadam Marg Lower Parel Mumbai - 400 013 Tel: + 91 22 4035 6300 Fax: + 91 22 4035 6400
New Delhi 6th floor, HT House 18-20 Kasturba Gandhi Marg New Delhi - 110 001 Tel: + 91 11 4363 3000 Fax: + 91 11 4363 3200 Pune C-401, 4th floor Panchshil Tech Park Yerwada (Near Don Bosco School) Pune - 411 006 Tel: + 91 20 6601 6000 Fax: + 91 20 6601 5900