Defining Target Populations for Winning Health Claims

Defining the appropriate target population is a crucial step in substantiating health claims under the European Nutrition and Health Claims Regulation. In this comprehensive blog, we'll explore the importance of aligning your study population with your target population, as well as the nuances and considerations involved in this process.

Table of Contents

• The Importance of Aligning Study and Target Populations
• Can Studies in Individuals with Disease Be Used?
• EFSA's Evaluation of Target Populations
• The Importance of Dialogue with EFSA
• Seeking Guidance Before Submission
• Conclusion: Navigating the Path to Successful Health Claims
• FAQ

The Importance of Aligning Study and Target Populations

Choosing the right study population is crucial for the success of health claims under the European Nutrition and Health Claims Regulation. It’s not just a formality; it’s the foundation of credible and reliable health claims.

Why Alignment Matters

The study population must reflect the target population to ensure the findings are applicable. When there's a mismatch, the results may not be relevant, leading to rejected claims.

Examples of Mismatched Populations

• Normal or low-normal body weight for weight reduction claims
• Morbidly obese individuals for general weight management claims
• Individuals with specific diseases for functional claims

Targeting the Right Group

For instance, if a health claim targets body weight reduction, the study should include individuals who are overweight but not morbidly obese. This ensures the findings are relevant to the general population.

Can Studies in Individuals with Disease Be Used?

Using individuals with diseases in studies can be a grey area. However, under certain conditions, these studies can still support health claims.

Conditions for Acceptable Use

If the effect named in the claim is expected to occur in healthy individuals, studies involving diseased individuals may be considered. This requires a strong rationale and justification.

Case Study: Lutein and Vision Loss

In 2018, a claim for lutein and reduced vision loss used a study population with macular degeneration. EFSA evaluated this and did not exclude it outright, indicating that early-stage, slowly progressing conditions might be acceptable.

Extrapolating Results

When using early patient populations, it’s essential to demonstrate that the results can be extrapolated to the general population. This involves showing that the effects observed in the diseased population are likely to occur in healthy individuals as well.

EFSA's Evaluation of Target Populations

EFSA evaluates claims meticulously, considering the target population and the study population used. This evaluation ensures the claim is relevant and scientifically substantiated.

Specific Examples

Consider the 2021 claim for saffron extract targeting low mood in individuals aged twelve and older. The study included patients with pharmacologically treated depression, and EFSA determined that these results couldn’t be extrapolated to the general population.

Determining Acceptable Claims

Determining what constitutes an acceptable claim is complex. It involves risk managers in the European Commission and member states, who decide if a claim aligns with the Nutrition and Health Claims Regulation.

Pathological Conditions vs. General Health

EFSA distinguishes between pathological conditions and general health. For example, a 2011 claim for spermidine aimed at prolonging the hair growth cycle was rejected because it targeted a specific condition rather than the general population.

Subtle Differences Matter

The wording of claims can significantly impact their acceptance. For instance, claims around hair growth need to avoid suggesting treatment of a pathological condition and instead focus on general maintenance of normal hair growth.

The Importance of Dialogue with EFSA

Engaging with EFSA early in the process can be a game-changer for companies looking to make health claims. This dialogue can help clarify key aspects, ensuring a smoother submission process.

Utilizing EFSA Connect

EFSA Connect is an invaluable tool for submitting pre-submission requests. It allows companies to seek guidance on various aspects, such as the admissibility of the target population in their study.

• Access through EFSA Connect portal
• Submit pre-submission requests
• Seek guidance on target population

Clarifying Early Concerns

Engaging with EFSA early can help address any concerns about the target population. This proactive approach can prevent potential issues later in the submission process.

It's a chance to refine your approach, ensuring alignment with EFSA's expectations. This can make the difference between a successful and a rejected claim.

Seeking Guidance Before Submission

Before submitting a health claim, it's crucial to seek guidance to ensure all aspects of the claim are aligned with regulatory requirements. This step can save time and resources.

Pre-Submission Requests

Pre-submission requests through EFSA Connect offer a way to get feedback on your planned study. This can help ensure your study design meets regulatory expectations.

• Ask about study design
• Clarify target population
• Get feedback on claim wording

Taking Advantage of Resources

Not enough companies take full advantage of the resources available through EFSA Connect. Utilizing this tool can provide valuable insights and guidance.

This can help refine your submission, making it more likely to be accepted. It’s a proactive step that can make a significant difference.

Conclusion: Navigating the Path to Successful Health Claims

Successfully navigating the path to health claims requires careful planning and engagement with regulatory bodies. Aligning study populations, seeking early guidance, and utilizing available resources are key steps.

Key Takeaways

Remember to align your study population with your target population. Engage with EFSA early to clarify any concerns and refine your approach.

• Align study and target populations
• Engage with EFSA early
• Utilize EFSA Connect

Final Thoughts

By following these steps, you can increase the likelihood of your health claim being accepted. It’s about being proactive and making informed decisions every step of the way.

Take advantage of the resources available, and don’t hesitate to seek guidance. This can make all the difference in achieving a successful health claim.

FAQ

To help you better navigate the complexities of aligning study populations with target populations for health claims, we've compiled a list of frequently asked questions. These address common concerns and provide clear, concise answers.

What is a target population?

The target population is the group for which the health claim is being made. This group should reflect the general population unless specified otherwise.

Why is aligning the study population with the target population so important?

Aligning these populations ensures that the study findings are relevant and applicable. Misalignment can lead to rejected claims.

Can diseased individuals be included in studies for health claims?

Generally, no. However, if the effect is expected to occur in healthy individuals and there is strong justification, it may be considered.

What are the conditions for using studies with diseased individuals?

Studies must demonstrate that the effects observed can be extrapolated to the general population. This requires a strong rationale.

How does EFSA evaluate target populations?

EFSA meticulously evaluates whether the study population reflects the target population. They ensure the claim is scientifically substantiated and relevant.

What should I do if I'm unsure about my target population?

Engage with EFSA early through EFSA Connect. Submit pre-submission requests for guidance on your study design and target population.

What is EFSA Connect?

EFSA Connect is a portal for submitting pre-submission requests. It allows companies to seek guidance on various aspects of their health claims.

Are there examples of successful and unsuccessful claims?

Yes, there are many. For instance, the 2018 lutein claim was ultimately unsuccessful due to methodological weaknesses, not the population used.

How can I ensure my health claim is successful?

Align your study and target populations, engage with EFSA early, and utilize available resources like EFSA Connect for guidance.

What are some common mistakes companies make?

Common mistakes include misaligning study and target populations and not seeking early guidance from EFSA.

Can pre-submission requests help refine my claim?

Absolutely. They provide valuable feedback on study design, target population, and claim wording, increasing the likelihood of acceptance.

What is the role of risk managers in the European Commission?

Risk managers in the European Commission and member states decide if a claim aligns with the Nutrition and Health Claims Regulation.

How can the wording of a claim impact its acceptance?

The wording can significantly impact acceptance. Claims should avoid suggesting treatment of a pathological condition and focus on general health benefits.

Can I use previous health claims as a reference?

Yes, reviewing previous health claims can provide insights into what has been accepted or rejected and why.

What are the benefits of engaging with EFSA early?

Early engagement can clarify concerns, refine your approach, and prevent potential issues, making the submission process smoother.

Is EFSA Connect accessible to all companies?

Yes, EFSA Connect is accessible to all companies looking to submit health claims. It's a valuable resource for seeking guidance.

What should I include in a pre-submission request?

Include details about your study design, target population, and claim wording. Be clear about the guidance you seek.

How can I demonstrate that effects observed in a diseased population are applicable to the general population?

Provide strong justification and evidence showing that the observed effects are likely to occur in healthy individuals as well.

What if my study involves a slowly progressing condition?

If there's no clear boundary between health and disease, you may argue for the inclusion of early-stage conditions, but ensure you can extrapolate results to the general population.

How can I avoid common pitfalls in my health claim submission?

Align your study and target populations, engage with EFSA early, use EFSA Connect, and review previous health claims for insights.

We hope this FAQ section helps address your questions and concerns. Remember, careful planning and early engagement with EFSA are key to a successful health claim submission.