Omega-3 Q&A with Gerard Bannenberg of GOED

So my name is Gerard Bannenberg. I'm a Dutchman. I work as GOED's technical director. GOED is a trade association. It's a global association of companies that all work in the EPA, DHA, omega-3 space. The association is composed of about two hundred and twenty companies worldwide, covering the whole supply chain of omega-3 oils: fish oil, microalgal oil producers, refiners, concentrators, contract manufacturers, brands and other companies that are in this area.

So we work together. This is a group of companies that exchange information on, for example, regulatory, scientific and technical topics. They may be competing in the marketplace, but in the background, through a trade association, they collaborate.

I work in the staff team and I take care mostly of technical topics. That's mostly assisting companies with technical questions or gathering occurrence data about the products members produce, and a lot of contact with external organisations that may want to know more about our sector. That's basically the background.

Yeah, so GOED members can use what we call the GOED Proud Member logo on their products. That's a logo that stands for the pledge that GOED members make when they join GOED: that they uphold the technical quality requirements and ethical behaviour that GOED sets for its members.

Companies are free to join GOED, but if they do, they are asked to pledge to abide by our requirements.

Well, we do have an internal randomised testing programme where we test our members' finished products. These are brands that have products on the market globally. Every year we test about twenty to twenty-four products for all the technical quality requirements that we set for our members. We also look at companies that join GOED, whether their products meet our standards.

We have our own monograph, which we call the GOED monograph, with the requirements for product quality. That also applies to ingredient oils, so oils that brands may use in their products. We're not a certifying company and we're not accredited to certify members. This is a logo from our association for our members.

There are many brands worldwide that are not GOED members and they don't have to abide by our quality requirements. They may do so voluntarily, but they don't have to.

Yeah, you should really see that as a quality standard. Consumers don't really have knowledge about the oxidative quality of the products that they buy. In many jurisdictions, many countries, there is no legal limit for oxidative quality. In that way, GOED was quite innovative already twenty years ago, setting a standard for the industry itself.

Consumers may have some information about oxidative quality if they go to the brand's website. Sometimes brands may offer batch-specific information about the products that they sell. That really depends on the brand.

Mm-hmm.

Yeah, no, that's clearly unacceptable. That signals a company that doesn't understand its own product, and they probably haven't done a stability study on their own product to see what goes wrong there. That's likely not using the correct antioxidants, or it may be just this batch.

When we observe such occurrences, the first thing you do is repeat the measurement to see if it holds up for the same product or other batches of the same product, or retainers held by the owner of that product. If that deviation is indeed observed again, repeated, then there's a serious defect with that product. Maybe an antioxidant that's unsuitable for omega-3 oils or a complete lack of antioxidants.

It's hard to say what may have happened there.

Yeah, well, as products get closer to the expiration date, they tend to have slightly increased values compared to when they have been recently manufactured. But we've done testing and we've looked at a whole bunch of different products from all over the world. If you then plot the remaining time to the end of shelf life and their oxidative quality, there is not really a clear relationship to be seen.

But I think if you follow an individual product over time, then you will see trends of increased levels of, for example, peroxide value or anisidine value, which stand for what we call primary oxidation and secondary oxidation over time. But within shelf life they should stay below the limits that we set, at least for GOED member products.

Well, if you talk about the biggest changes that can happen, that's really when a consumer opens the supplement bottle for the first time. That's when air rushes into the product and when antioxidants start doing their job in protecting the oil from oxidation.

Usually there is protection that lasts for several weeks, within the specified time that a consumer is supposed to finish the bottle of softgels or liquid oil, within the stated period that the dose should be consumed. So the daily serving size and the number of capsules in there. If a consumer stays within that recommended daily serving size, oxidation shouldn't be a major issue.

But that's where the largest changes can happen, especially if the product is left for a long time on a shelf or in a cupboard, especially in light or under warmer conditions. Then oxidation really takes off after some time. By that time, consumers themselves will find the product pretty awful-smelling and won't even consume it anymore. That's where the big changes would happen.

But of course, these fatty acids are extremely sensitive to oxidation, so at any step that's not properly controlled, there is a risk of oxidation. That's where manufacturing has really learned how to control these substances: treat them very gently, no exposure to air, low-lighting conditions.

I think overall the industry knows how to handle these products. A brand should know how to manage the stability of the product during storage, and then the major change will happen at the consumer's end.

Yeah, they should. I mean, I wouldn't—it's hard to say. If it's seventeen times over the limits that we set for oxidative quality, then that product will really have an off-flavour. It will really be smelling pretty bad. So a consumer wouldn't even consume it.

Most likely. Yeah, I haven't seen the product myself, but I would expect it to be pretty bad.

Yeah, it's a good question. As I said, the limits we set are quality standards. They're not safety standards. The body is pretty used to dealing with oxidised components in our food. Nevertheless, anybody should be concerned about possible safety issues with highly oxidised food products.

But at the very low levels of oxidation at which these limits are set, the levels are so low that I don't think there is any concern about safety. Maybe one millilitre or one gram of an omega-3 product a day, at the very low oxidation levels that we're talking about, I think there's no concern for safety.

Actually, our nose is very sensitive to oxidation. Just above the quality limits that we set, a product will already start to smell a little bit. Then it's the consumer who will decide for themselves if they find the product still attractive if it's slightly above the quality limits that we set.

Well, for GOED members, yes, that's what we expect from our members. As I said before, there are many brands globally that are not members of GOED and they don't follow our limits. But they may be following other limits, or should be following other limits, for example set by pharmacopoeial monographs.

The major jurisdictions, like the European Union, US, Canada, Australia and Japan—many countries have their pharmacopoeia, and those pharmacopoeias may also have limits for oxidative quality. A brand that's serious about its products will follow a quality monograph for its products.

One has to understand that dietary supplements, food supplements across the world, are produced under current GMP conditions. This is not an unregulated sector; it's actually a very highly regulated sector.

Mm-hmm.

Well, if it says third-party tested, at least you know that the product has been tested independently from the supplier of the product or the ingredient and the brand itself. It helps if the brand then offers the consumer information about the testing that has been performed for that particular batch of product.

Otherwise, it's not easy for a consumer to know exactly what the quality of the product is just from the label. But third-party testing is a minimum requirement, I think, to offer some kind of trust that the quality is assured. Also, that the measurements have been carried out accurately. That's very important.

Yeah, so our GOED monograph sets quality requirements for oxidative quality, as we've just discussed, but also for several environmental contaminants. These include heavy metals, for example lead, mercury, cadmium and inorganic arsenic, and also some persistent organic contaminants like dioxins and furans, PCBs and dioxin-like PCBs.

These are typically regulated globally, but GOED sets these limits as minimum requirements too. Usually, if members meet GOED's requirements, their products will meet any limit for these contaminants globally as well. There are contaminants that are regulated in specific jurisdictions. For example, the European Union is very active in regulating many contaminants.

GOED doesn't cover all of the regulated contaminants globally. But we do offer a lot of support to our members to meet those other contaminant requirements that may be relevant in different jurisdictions.

Besides contaminants and oxidative quality, we also provide recommendations on which methods to use to accurately quantify EPA and DHA and what we call total omega-3 in the dietary supplements and ingredient oils that our members produce. That's important because there are many methods that are not developed or validated for omega-3 oils. They may have been developed originally for other food products, like milk or vegetable oils, and they are not really taking into account the specific analytes and conditions that you need to take into account to accurately measure EPA and DHA in fish oil, for example.

Yeah, those can be pharmacopoeial methods, and they can also be from international organisations specialised in the analysis of lipids, for example the American Oil Chemists' Society. GOED also has its own method that we recommend to members. Our monograph or a separate document lists the complete method to be executed.

Actually, that's open to anyone. If you go to our website, you can look at our GOED monograph, but also at these technical guidance documents that provide a lot of really helpful, specific information on how to handle and analyse omega-3 oils.

Well, one easy way is to look at products that have this GOED Proud Member logo. At least you know that it's from a company that abides by a very high quality standard. There are other labels that suggest good quality. There's a label from NSF and USP Verified. These reflect good quality products.

You may want to go to the brand itself, its website, and read about the product. Yeah, as you said.

Exactly. It's hard for a consumer to get all the data about an individual product. That's true. But get in contact with the brand if you have the stomach for that, or go to the website.

Exactly.

Yeah, that can help. Consumers can also reach out to organisations like us if they want to get specific information. Not about individual products—that's the responsibility of the brand. But general information, we're pleased to help.

Consumers are very sensitive to other aspects of a product as well. Presentation and packaging are very important factors for consumer purchases. Price, of course. Consumers also have very specific requests. For example, they may want a certain size of softgel because that's what they prefer to consume. Or they may prefer to take omega-3 as a liquid supplement, which is very popular in certain geographies. There are many factors that determine product choice by the consumer.

Hmm. Yes.

Yeah.

Yeah, exactly.

Yeah.

Yeah, exactly. Yeah.

Okay. What's important to understand is that when people talk about oxidised fish oil, you have to really clarify what you're talking about. Do you mean something that's totally rancid and all the EPA and DHA in the product has been consumed and oxidised? Or do you refer to something that's just above a quality limit and call that oxidised?

Being just above the quality limit doesn't mean that the product suddenly is completely rancid and completely destroyed. This is a gradual level of quantitative expression of oxidation. Within that quantitative expression, there are many different factors. You have to think about primary oxidation and secondary oxidation, and all these parameters are composed of many different substances.

Each product is different, has its own composition profile and, if there is some oxidation occurring, totally different profiles of oxidation products as well. It's very hard to generalise anything about oxidation. We set quality limits that kind of guarantee that there are no issues regarding smell or off-flavours, let alone safety issues. But even if you're above those limits a little bit, there's probably no reason to be concerned. It's a complex topic.