Food for Special Dietary Use for Sportsperson

Introduction:

This Guidance Document on “Food for Special Dietary Use for Sportspersons” is the outcome of a collaborative effort at the national level to promote use of dope-free food supplements and nutritional products for sportspersons and to develop and strengthen cooperation in the fields of Sports Nutrition including nutrition practices that enhance lifelong health and fitness of  sportspersons.

Food for Special Dietary Use for Sportspersons (FSDU for Sportspersons) contain ingredients required to achieve specific nutritional and performance goals. However, there have been instances where such food may be laced with prohibited substances resulting in unintentional doping. Therefore, it becomes imperative that the sportspersons must have proper guidance on such food and nutritional products so as to ensure that they make informed choices while purchasing these products.

This guidance document attempts to educate the sports fraternity (sportspersons, sports nutritionists, health professionals and coaches) and general public on various types and forms of supplements available in the market; their selection criteria as per requirement; dosage; labelling and claims provisions; authenticity, traceability and source. In addition, the guidance document
also provides for:

• Information on current regulatory framework;
• Guidelines that should be followed by Manufacturers, Importers and Retailers;
• World Anti Doping Agency and its list of Prohibited Substances and Methods (2019);
• National Anti Doping Agency, Anti Doping Rules, Strict Liability Clause and Therapeutic Use Exemption for sportspersons;
• Definitions and Frequently Asked Questions;
• Web Links for Nutrient Requirements and Recommended Dietary Allowances for Indians (2010), Dietary Guidelines for Indians-A Manual (2011), IOC- Consensus Statement: Dietary Supplements and the High-Performance Athlete;
• Recognized Sports in India.

Definitions:

Sports: an activity involving physical exertion and skill in which an individual or team competes against another or others for entertainment;

Sportsperson: means an individual who is involved in various types of sports activities as approved by Sports Authority of India (Ministry of Youth Affairs & Sports);

Food for Special Dietary Uses (FSDU) for Sportspersons: FSDU for Sportsperson is a specifically processed or formulated product that satisfies particular dietary requirements which may exist or arise because of certain sports and related physical activities;

Ergogenic aid: a physical, mechanical, nutritional, psychological or pharmacological substance or treatment that either directly improves physiological variables associated with exercise performance or removes subjective restraints which may limit physiological capacity;

Nutritional ergogenic aid: substance found in the diet that is ingested in an effort to produce improved or enhanced sport, exercise, and physical performance;

Nutrient Ingredient: means a vitamin, mineral, or amino acid as specified in Schedule I and Schedule II of the FSS (Food or Health Supplements, Nutraceuticals, Foods for Special Dietary Uses, Foods for Special Medical Purpose, Functional Foods, and Novel Food) Regulations, 2016;.

Prohibited Substance: Substance/ ingredient /drug prohibited by WADA for use by sportspersons.

Current Regulatory Framework and Status:

1. a)    Food Safety and Standards Act, 2006/ Regulations:

Section 22 of the Food Safety and Standards Act, 2006 defines “Food for special dietary uses or functional foods or nutraceuticals or health supplements” as “ food which are specially processed or formulated to satisfy particular dietary requirements which exist because of a particular physical or physiological condition or specific diseases and disorders and which are presented as such, wherein the composition of these foodstuffs must differ significantly from the composition of ordinary foods of comparable nature, if such ordinary foods exist, and may contain one or more ingredient….. . Further, Section 22, Subsections b(i), (ii) & (iv) lay down the following provisions: –

• a product that is labelled as which is not representing a conventional food and where such products may be formulated in the form of powders, granules, tablets, capsules, liquids, jelly and other forms and are meant for oral administration (not parenteral);
• such product does not include a drug as defined in clause (b)and ayurvedic, sidha and unani drugs as defined in clauses (a) and (h) of section 3 of the Drugs and Cosmetics Act, 1940 (23 of 1940) and rules made there under;
• does not include a narcotic drug or a psychotropic substance as defined in the Schedule of the Narcotic Drugs and Psychotropic Substances Act, 1985 (61 of 1985) and rules made there under and substances listed in Schedules E and EI of the Drugs and Cosmetics Rules, 1945.

The Food for Special Dietary Use is also covered in the Food, Safety and Standards (Health Supplements, Nutraceuticals, Foods for Special Dietary Uses, Foods for Special Medical Purpose, Functional Foods, and Novel Food) Regulations, 2016 which covers eight categories of foods, namely, Health Supplements, Nutraceuticals, Food for Special Dietary Use, Food for Special Medical Purpose, Speciality Food containing plant or botanicals, Foods containing Probiotics, Foods containing Prebiotics and Novel Foods. Requirements for such foods as detailed in these regulations pertain to essential composition; claims and labelling provisions. These standards also include the essential composition, requirements related to claims, labelling, permitted use of additives and the permissible limits of contaminants, toxins and residues. The regulations do not allow the use of hormones or steroids or psychotropic ingredients in any of the articles of food. Furthermore, these regulations provide various Schedules dealing with use of vitamins and minerals, amino acids, ingredients of plants or botanical origin, nutraceuticals, probiotics and prebiotics in these
products. The sub category under FSDU shall cover FSDU for Sportspersons considering their special needs.

Guidance for Sports Fraternity, Manufacturers, Importers, Retailers & General Public:

FSDU for Sportsperson may be required to help sportsperson to meet the expenditure of energy during intense muscular effort, to improve exercise performance capacity, improve the efficiency of
exercise, enhance recovery from exercise, tolerate intensive training and remain healthy.

FSDU for Sportsperson can be broadly divided into the following categories:

• Carbohydrate-rich energy food products: products high in glycemic carbohydrates essential 0before, during and after exercise for providing energy and refueling glycogen storage.
• Carbohydrate-electrolyte fluids: Fluids providing carbohydrates as the major energy source and effective in maintaining or restoring hydration status.
• Protein and protein components: high protein and essential amino acids products ensuring endogenous synthesis of proteins, muscle maintenance/gain, and glycogen synthesis when combined with carbohydrates.
• Enriched foods with supplements such caffeine or creatine: some dietary ergogenic aids
• Enriched foods with vitamin and mineral supplements

FBOs are required to adopt the following practices: – 

1. Registration and Licensing of Manufacturer with FSSAI :

• Manufacturer (Domestic or International) should have an Indian registered office with local contact details for addressing consumer grievances.
• Manufacturing facility should be periodically audited as per FSSAI Regulations.

2. Labels and Claims: FBOs should ensure that the following declaration are printed on label of the package containing FSDU for Sportspersons: –

• “FOR SPORTSPERSON ONLY”
• Logo (This logo is a part of amendment proposed in the Food Safety and Standards (Health Supplements, Nutraceuticals, Food for Special Dietary Use, Food for Special Medical Purpose, Functional Foods and Novel Foods) Regulations, 2016 and this will be implemented on the date of publication of said final amendment)
• “Recommended to be used under medical advice or dietetic supervision only”
• the product is not to be used by pregnant, nursing and lactating women or by infants, children under 5 years and elderly except when medically advised”
• the food is not a sole source of nutrition and should be consumed in conjunction with a nutritious diet’ for the article of food specially prepared for sportsperson;”
• the food should be used in conjunction with an appropriate physical training or exercise regime.”
• “for oral consumption only”

General Public:

Consumers must be aware about the difference between general health or food supplements and the food supplements for sportspersons. They must read the label and claims, and must be aware of the prohibited substances as per WADA. In addition to this, consumers should: –

• Choose/select supplements as per their requirements or recommendation by sports nutritionists, health professionals or coaches.
• Confirm the dosage required by them as per their daily activity, gender and age.
• Check Expiry Date/Best Before Date before buying online and offline;
• Look for tamper proof /tamper evident packing;
• Use authentication system provided by Manufacturer;
• In case of grievances/query, customer, contact the manufacturer as per the given customer grievance details.

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