Members of the European Parliament’s Committee on the Environment, Public Health and Food Safety (ENVI) have just green-lighted proposed new rules for total diet replacement (TDRs) products. These are foods, such as Nestlé Health Science’s Optifast, that are trying to position themselves as a magic bullet for obesity and type 2 diabetes. These products have remarkably little evidence to support their use for their intended purpose and rely on minimising calorie intake (to as little as 600 kcal per day). Despite their “nutritionally complete” claim, these Very Low Calorie Diet (VLCD) products used as total meal replacements could also represent a serious risk to health because of their grossly imbalanced macronutrient composition.

Despite opposition from the trade body, Specialised Nutrition Europe (SNE), the proposed new rules will affect Low Calorie (LCD) and Very Low Calorie Diet (VLCD) products intended as total meal replacements, such as shakes and bars.

The proposed new rules contained in a draft European Commission delegated regulation require that total meal replacement products should contain a minimum of 75g of protein (previously 50g) and increased levels of two essential fatty acids per daily ration.

The home of ENVI, in the European Parliament, Brussels

This advice echoes certain aspects of an opinion from the European Food Safety Authority (EFSA) from 2015 such as protein intake, with 70-100g per day having been shown to be associated with weight reduction in obese patients. However, EFSA did not take into account diets with such limited energy, and the draft delegated regulation ignores EFSA’s adequate intake (AI) recommendation from 2010 for 250 mg/day of the n-3 (Omega 3) fatty acids DHA and EPA.

As they say, the ‘proof of the pudding is in the eating.’ Here, it seems the use of VLCD products has had little impact on the still spiralling rates of obesity and type 2 diabetes. These diet strategies are at best short-term, leaving people feeling hungry and deficient in essential nutrients and they don’t teach people how to maintain weight loss through healthy eating habits and lifestyles. Worse, increased weight gain following use of a VLCD strategy is very common, often leaving people more obese and unhealthy than before they began.

Dangerous Dieting

We have concerns about the proposed new delegated regulation, but unlike SNE that’s worrying about the difficulty of making products that taste good or that have a high enough profit margin, we’re worried about their potentially serious untoward health effects.

Imagine a VLCD shake product providing 200 kcal, recommended for use 3 times daily to provide 600kcal of total energy. If it then contained, as the draft regulation requires, between 75 and 105 g of protein, that would deliver 50-70% of its energy from protein. That compares with the US National Academies’ dietary reference intake for protein of between 10-35% of energy intake. A VLCD product could provide this high protein intake while providing, legally, just 1.4 g of alpha-linolenic acid and 11 g of linoleic acid, representing just 17% of energy as fat, with the remainder coming from carbohydrates which could be predominantly as sugars. On the sugars front, let’s remember that Nestlé’s Optifast provides a stunning 36% of its energy from sugars, this being 7-fold over the UK Scientific Advisory Committee on Nutrition’s advice (2015) which proposes that not more than 5% of energy should come from free sugars.

Based on all available nutritional research, including the latest PURE (Prospective Urban Rural Epidemiology) study, this represents a highly imbalanced composition of macronutrients that does not promote beta-oxidation of lipids (fat-burning) and does not provide an appropriate balance of essential fatty acids to help modulate inflammation and for proper brain, neurological or cardiovascular function.

Obesity and type 2 diabetes: there is no magic VLCD bullet

Obesity and other nutrition-related metabolic diseases are both complex and multi-factorial health problems born out of our increasing reliance on industrially produced foods coupled with sedentary lifestyles. Obesity and type 2 diabetes can however be successfully reversed and managed by working with the body to encourage proper function of metabolic processes in line with our genetic blueprint, especially strategies that encourage nutritional ketosis.

Our Food4Health guidance is an information resource that aims to help people to adopt a healthier diet and lifestyle, including achieving and maintaining a healthy weight, along with improved resilience and vitality.

Call to action

We are in the process of dialogue with ENVI members given our concerns that the draft delegated regulation could represent a significant risk to the health of overweight and obese people. It is an example of a draft legislative proposal that has been produced by regulators subject to pressure and influence from various industries while being informed by scientists working in a vacuum.

European citizens: please write to your MEP and let him/her know that the draft regulation may pose significant risks to human health and is highly unlikely to help reduce spiralling rates of obesity and type 2 diabetes. For ease, you can reference this article or information within it.