we have read the attached draft of the new article you are going to publish on your blog.
Please, note our comments on it.
1. The AIC opinion on the COM 353/2011 issue has always been the same: foods specially produced to meet the special dietary needs of coeliacs, like bread, pasta, biscuits, need a higher level of safety and controls than foods for normal consumption suitable for coeliacs, like meat products, soups, ice creams, etc.
Products specifically formulated for coeliacs are basic food in their diet, because they guarantee the compliance to the gluten-free diet, the only therapy today known for coeliac disease.
2. We do not believe that these additional protective requirements on foods specially produced for coeliacs could affect or reduce celiac consumer choice, but, rather, would protect their health, the first objective of an Association of patients.
3. The AIC considers coeliacs a vulnerable category of consumers as they need special protection: to access to a SAFE gluten free diet, to have a right diagnosis (diagnosis is still underestimated and subject to mistakes). The AIC position aims to protect all people with celiac disease, not just Italians, from a disqualification of the concept of celiac disease, that is an illness severe and chronic. The AIC claims that the European Union should recognize that coeliacs are a vulnerable group of citizens, to be protected.
4. The position voted by the European Parliament in June and supported by the AIC recognized, for coeliacs, the status of vulnerable category of consumers and, for foods specially produced to for coeliacs, the status of health foods essential to their diet, a fundamental principle for the protection of coeliacs in Europe. This first important vote, as stated by the AIC in its press releases, left room for consultation in order to maintain the possibility for foods for normal consumption, to use the claim "gluten-free". In this regard, the AIC has always required to maintain the possibility provided for in Article. 4 of the Regulation 41/2009 (that also food for normal consumption can use the claim "gluten-free").
5. As usual, there are different positions on the issue, due to specific national circumstances. Yet, it's ridiculous to consider the Italian position - supported by the Italian Coeliac Association, by the main Italian Association of Consumers (UNC Unione Nazionale Consumatori) and by the Italian Government - as the result of pressure from economic interest groups. Far from being “ambiguous", the Italian Government, AIC, UNC and AIIPA have always been consistent, clear and transparent in supporting this opinion on the COM 353 issue.
6. Please, note that the Italian situation is not as described in the article, particularly when it comes to "But with more and more regular foods carrying the “gluten free” marking, the Italian health insurance is having trouble deciding which gluten free foods to reimburse: the additional costs of reimbursing normal foods no doubt threatens Italy’s “gluten free” reimbursement system.” The Italian National Health Service reimburses only the gluten-free dietetic products (i.e. food that is specifically formulated for coeliacs). The reference to the sentence of the Ministry "It appears necessary to revise the register of reimbursable dietetic products for celiacs, whereas rules on the [European] Community level, such as Regulation (EC) 41/2009 under certain conditions allow foods for normal consumption to carry the label “gluten free” as well" refers to particular categories of products, such as breaded products, NOT to foods for normal consumption, which are NOT reimbursed by the Italian National Health Service.
7. The AIC has worked in a transparent way in the past months, declaring publicly and openly our collaboration with AIIPA on this specific issue, and we believe that the reference to the first revision of the AIC document quoted in the article is pretextual and specious, since AIC, AIIPA and UNC have produced in recent months many joint papers.