Codex Overview and Report on Bonn, 2004

(Taken from Death by Modern Medicine (March 2005) by Carolyn Dean, MD, ND with Trueman Tuck)

There is a groundswell of concern in North America and Britain because of the efforts of an organization called Codex Alimentarius to regulate food and food supplements for the World Trade Organization (WTO). Codex Alimentarius, from the Latin, meaning Food Law, is usually referred to simply as Codex.

The United Nations Food and Agricultural Organization (FAO) and the World Health Organization jointly established Codex in 1962 to help advise nations on food standards for consumer protection. Peter Helgason and I attended the 26th Session of Codex in November 2004 on behalf of health freedom group, Friends of Freedom. It was at Codex in Bonn that we met a 30-year employee of Codex who told us that in 1995, the World Trade Organization took over Codex undermining its original intent. It was no longer in the hands of the 165 member nations of the WHO but in the hands of trade organizations in the 148 countries of the WTO who seem intent on standardizing everything to do with international trade in our emerging global economy. According to complex world trade agreements, which corporations and governments have created with very little public input or support, the decisions of Codex override national and local laws.

The main issue for health consumers is how Codex rules will affect our access to “food supplements”. In countries where supplements are classified as drugs, Codex, apparently does not interfere, which sends a strong message to member countries to regulate their supplements as drugs leaving the rest of the world to fend for itself. In countries where supplements are still classified as food, Codex is developing, what appear to be, stringent rules to govern the so-called safety of these products exactly along the lines used for drugs. So, dietary supplements actually all end up in the same drug pot. It’s very much like asking your child if he wants the drug in your right hand or the drug in your left hand-there is no choice at all. Food and supplement quality and purity are legitimate avenues for governments to pursue, however, Codex is setting limits on the amount of supplements that an individual consumer can purchase without a prescription. They are using the same scare tactics as outlined in the Canadian Natural Health Products Directorate by saying supplements are dangerous.

Discrediting Dietary Supplements
Unfortunately, Codex is run along the lines of the prevailing vitamins-for-deficiency lobby, which judges vitamins as dangerous and only safe in RDA dosages. If this continues we will be less able to treat the current epidemic of chronic vitamin deficiency diseases. You may have noted in the last year a number of headlines announcing that this or that vitamin is dangerous or shortens life in a particular research study. All these studies, when reviewed, have serious flaws, or have mysteriously reached the opposite conclusion of the actual study results. We see this as a pervasive policy to discredit supplements and scare legislators and the public into accepting supplement regulations. Please remember that dietary supplements are not dangerous.

It is quite apparent to those who have been following Codex and attending
their meetings, such as Trueman Tuck, Peter Helgason, and Dr. Carolyn Dean
of Friends of Freedom ( in Canada; John Hammell
founder of International Advocates for Health Freedom (, Suzanne Harris JD, of The Law Loft, Diane M Miller
JD executive director of the National Health Freedom Coalition
(, Suzan Walter of the American Holistic Health
Association (, and Scott Tips of the National Health
Federation ( in the U.S.; Paul Taylor in the UK for the
National Health Federation; and Tamara Theresa Mosegard from the
organization May Day in Denmark that the Codex agenda for dietary
supplements is that of the pharmaceutical companies. Scott Tips, legal
counsel for the National Health Federation has been attending Codex meetings
for about five years and manages to have a voice at Codex because his group
is a recognized NGO. In most meetings, the NHF is the lone voice supporting
health freedom. Big Pharma has enjoyed a monopoly in medicine for many long decades. The public, however, is becoming aware of the dangers of modern medicine as documented in “Death by Medicine”. Big Pharma does not want to lose its lucrative monopoly and is lobbying governments and Codex for restrictive legislation on the supplement industry and simultaneously, systematically, and silently buying up supplement companies to control the market.

I see this happening first hand in Canada. When I practiced traditional medicine in Toronto from 1979-1991, I witnessed the birth and rise of the traditional health movement in Canada. I still know some of the owners of supplement companies, big and small. The sad fact is that being ‘regulated’ by the government means paying tens of thousands of dollars in fees and licenses to be able to sell your products. Small companies are being forced out of business-or forced to sell to companies with deep pockets, who are often fronting for pharmaceutical companies. The larger supplement companies, whether independently owned or Big Pharma holdings can afford these registration fees and are ‘all about business’ and less ‘about’ wellness and the public welfare. They are probably happy to see their smaller competitors driven out of business as they follow the business trend toward monopoly.

It is another sad fact that government seems to be controlled by ‘big business’ and has adopted the attitude that we call legislating and legalizing corporate greed. At the Codex meeting in Bonn, Germany that I attended November 1-5, 2004, when delegates raised important concerns they were always told, “Another committee is handling that issue”. That answer was given when the chairman was asked whether genetically engineered foods were going to be allowed in infant formula. I would have thought that a simple “Of course not.” answer that question, which implied to me that they are actually considering using GMO foods in infant formula.

A question by a Non-Governmental Organization (NGO) delegate about the inclusion of provitamins and vitamin-like substances brought the following answer from the chair. “We first wanted to discuss vitamins and minerals. In the future, in 10-20 years time we will have to discuss physiological plant substances.” Does that mean that if the Codex guidelines for supplements leave out certain nutrients that those nutrients will no longer be considered “regulated” and disappear from the shelves. That very scenario is playing out in the U.K. now. Under the EU Food Supplement Directive 5,000 products are slated for removal from the shelves.

The UK Battles the EU to Keep Supplements
In retrospect, it appears that government agencies of many nations have been on a common track for decades to have supplements designated as drugs. Australia, Denmark, Germany have all rendered their dietary supplements essentially impotent by regulating them as drugs and drastically limiting the amounts that may be sold without a prescription.

The European Union’s Food Supplement Directive is a likely model for the type of dietary supplement restrictions that Codex will try to implement worldwide. Passed into European Law in 2003 the EU Food Supplement Directive will be transposed into the legal systems of all other EU member states. In 2004, the U.K. government, against the wishes of its citizens, agreed to accept the EU Food Supplement Directive as law. Ireland, the Netherlands, and Sweden are facing similar enforcement. This law will, in effect, ban about 300 of the 420 forms of vitamins and minerals present in around 5,000 products on the U.K.

Working to declare this measure illegal is the Alliance for Natural Health (ANH) ( led by executive director, Dr. Rob Verkerk, PhD. ANH is a pan-European coalition of supplement manufacturers, retailers, independent health practitioners, and consumers. On October 13, 2004 ANH filed a lawsuit to force a European judicial review of the EU Food Supplement Directive, which is slated to be fully operational in the U.K. by August 2005.1

About the lawsuit, Dr. Verkerk said “This is a groundbreaking challenge to another intrusive and unwanted EU Directive ban which we aim to demonstrate has been passed unlawfully from the EU into U.K. law. We believe that it will rob the consumer of the right to buy important nutritional supplements to improve their diet and health and that of their children, as well as putting hundreds of small businesses and the livelihoods of thousands at risk. There is absolutely no justification for this ban and we aim to get it removed.”

Dr. Verkerk, ANH, and their supporters are extremely concerned that this draconian measure will ban ingredients that include natural forms of vitamin E, found in wheat germ and organic bound minerals like selenocysteine, found in brazil nuts. In addition the directive aims to ban nearly all important trace elements used in supplements, including boron (necessary for bone production) and vanadium (useful in blood sugar regulation).

Especially targeted to be eliminated, says Dr. Verkerk, are high quality products made from natural ingredients, whereas synthetic vitamins and inorganic minerals, typically pervasive in multivitamin and mineral products found in supermarkets and pharmacies, will not be affected by the ban. These low quality products are the nutrient forms approved by the EU directive. In Bonn, the only multiple that we could find was Centrum, the synthetic multiple made by Wyeth Pharmaceutical company, which any hospital nurse will tell you, usually lands in the bedpan with a thud, fully intact.

Dr. Verkerk adds that another effect of the EU legislation is that many small companies who research, produce, and market safe and effective food supplements will be unable to sell them without investing huge sums of money to “prove” their safety. This is despite the fact that people have been consuming most of these food-based nutrients for sometimes hundreds of years with no known health risk.

On the Codex front, Dr. Verkerk has produced a brilliant paper to counter the attempt by Codex to devise the amount of supplements allowed to be sold on the world market based on risk analysis.2 As we have stated repeatedly, there is no risk to dietary supplements, they are safer than the food chain, yet the Codex machine pushes on trying to say they are unsafe and need to be limited and regulated. You can read Dr. Verkerk’s 35-page submission to the FAO/WHO Nutrient Risk Assessment Project on behalf of the Natural Health Alliance at the link provided.2

It is the same nonsense that is happening in Canada and is soon to happen in the U.S. as regulators are turning up the heat as they spread rumors about dangerous supplements. It’s time to turn to the back pages of Death by Modern Medicine and join consumer groups, write letter, and lobby your members of parliament, congressmen, and senators.

North America Must Hang Tough
In the U.S. the fact that dietary supplements are regulated under a food designation according DSHEA, which as passed in 1994, is extremely critical to both the U.S. and Canada. The priority for Americans is to protect and expand DSHEA. The U.S. is one of the few countries in the world that has protected food-based medicine with specific legislation. Big Pharma and its friends continually try to undo that legislation. The second focus for Americans should be to support Canada’s health freedom movement. In Canada, we continue to fight for Bill C-420 to get our supplements back to a food designation. Canada and the US fought similar battles around 1994 and in 1997 Canada saved its supplements but we didn’t implement legislation like DSHEA. And as we’ve mentioned several times on January 1, 2004 our dietary supplements became drugs by a regulatory maneuver, not a law.

Canada’s new drug category is bad news for dietary supplement manufacturers in the U.S. who want to trade with Canada. We will see the government of the U.S. trying to implement a drug category for dietary supplements on the basis of free trade agreements. If Canada’s dietary supplements are forced to stay in the drug category then the U.S. will stand alone in the world as a major Western country with food-based supplements. Most other countries have adopted the drug category. We must expand our beachhead to so that Canada and the U.s. work together for our right to freedom of choice in health care. The third focus is for North America to support the U.K. as it fights the EU Food Supplement Directive. Together we can then all work to overturn Codex.

The Delphi Technique at Codex
The Delphi Technique was created to give a facilitator tools that would ensure control of the outcome of a group decision manipulating the group to think it was participating in the making of that decision. The Delphi Technique only works if the facilitator is able to destabilize anyone who might think independently of the group. To make Delphi work the group must not be permitted to align with a natural leader who could challenge the ideas of the facilitator. Other aspects of implementing Delphi are to ask questions that divert the group away from core issues that many people might be concerned about. And, lastly, the group is driven to achieve “consensus” rather than voting on the issues. If a strong member of the group votes against the facilitator that person may sway the group, therefore, the facilitator manipulates the group into thinking consensus is being reached. Of course, facilitators always manage to manipulate the consensus to their own ends. I was unfamiliar with this psychological manipulation method until I went as a delegate to the meeting of Codex Alimentarius in Bonn.

According to Lynn Stuter, it is a “consensus building” technique that Lynn says is surely “leading us away from representative government to an illusion of citizen participation”.3 She says, “In group settings, the Delphi Technique is an unethical method of achieving consensus on controversial topics. It requires well-trained professionals, known as “facilitators” or “change agents,” who deliberately escalate tension among group members, pitting one faction against another to make a preordained viewpoint appear “sensible,” while making opposing views appear ridiculous.”

At Codex the word “consensus” was used constantly and no vote was ever taken. The Chair somehow determined that, voila, we have achieved consensus and moved on. Delegates had to be quick to press their buttons to take exception to his ruling. But, as I found out later, the Chair could very easily ignore a request for the floor. I could see that after a while you would become so frustrated that you threw up your hands and just gave up trying. There were stories of delegates yelling out to be heard that ended with the delegate being immediately removed from the room and banned from future Codex meetings. Punishment at Codex is swift.

When Peter Helgason, VP of Regulatory Affairs for Friends of Freedom, who also attended the Bonn meeting, told me the chairman was using the Delphi Technique, it all clicked into place, I could see exactly what he was doing. And I see how Project 2000 in British Columbia (See Chapter 1) works as well. Discredit the opposition with lies until they get so hysterical at being lied about and lied to that they scream at you. Then you have won; you can denounce them for being hysterical. It’s used all the time and it works every time.

One of the most frightening episodes I witnessed at Codex was when a non-governmental organization (NGO) delegate from a group supporting breastfeeding spoke. Her request to speak was recognized by the chair. She stood up and said that her organization did not want to see bottle formula advertised in developing nations. As she recalled the deaths caused in Africa by mothers abandoning breastfeeding for the bottle the Chair quickly (and emotionally in my opinion) cut her off and accused her of bringing emotion into the meeting. He said this was an issue of labeling and not of emotion. He humiliated her and her point of view and, as common with the Delphi Technique, tried to make her appear ridiculous, and he certainly escalated the tension in me!

I could not believe much of what I heard that week in Bonn. I could not believe the total lack of respect and the blatant disregard for the human race at that meeting. I could not believe how Codex is completely controlled by the World Trade Organization to make the whole world into a shopping mall.

There are ways to diffuse the technique when you see it being used by Delphi “facilitators”. Lynn Sunter gives the following three simple steps.

1. Always be charming, courteous, and pleasant. Smile. Moderate your voice so as not to come across as belligerent or aggressive.

2. Stay focused. If possible, jot down your thoughts or questions. When facilitators are asked questions they don’t want to answer, they often digress from the issue that was raised and try instead to put the questioner on the defensive. Do not fall for this tactic. Courteously bring the facilitator back to your original question. If he rephrases it so that it becomes an accusatory statement (a popular tactic), simply say, “That is not what I asked. What I asked was . . .” and repeat your question.

3. Be persistent. If putting you on the defensive doesn’t work, facilitators often resort to long monologues that drag on for several minutes. During that time, the group usually forgets the question that was asked, which is the intent. Let the facilitator finish. Then with polite persistence state: “But you didn’t answer my question. My question was . . .” and repeat your question.

The key is to never, ever become angry. Their key to success is to make you angry, which makes the facilitator the victim and you become the bad guy. Sunter says that facilitators work to achieve group consensus by trying to make the majority of the group members like them, and to alienate anyone who might pose a threat to the realization of their agenda. People with firm, fixed beliefs, who are not afraid to stand up for what they believe in, are obvious threats. On the other hand, if the facilitator seems to be directly putting down a participant then the participant becomes a victim and the facilitator loses face and favor with the crowd. Sometimes you can goad a facilitator into becoming mad at you. She says, this is why in many forums now, crowds are broken up into groups of seven or eight, and objections are written on paper rather than voiced aloud where they can be open to public discussion and debate. It’s a form of crowd control.

At a meeting, if you have two or three people who know the Delphi Technique dispersed through the crowd, when the facilitator digresses from a question, they can stand up and politely say: “But you didn’t answer that lady/gentleman’s question.” The facilitator may suspect certain group members are working together but he knows better than to alienate the crowd by making accusations. Sunter says it sometimes only takes one incident of this type for the crowd to figure out what’s going on.

Read up on the Delphi Technique and think of all the times you have seen situations controlled by this process and refuse to be controlled by such tactics ever again. The following reference is for a woman, Beverly Eakman whose books and seminars teach you how to avoid group manipulation.4

Action Steps:

1. Join Friends of Freedom International, our international organization committed to getting delegates to Codex that will demand human person’s rights and not just artificial person’s rights (corporations). Read about our Canadian work at and go to and click on membership. Join and donate generously to send delegates from developing nations, as well as Trueman Tuck, Peter Helgason, and Carolyn Dean to Codex.

2. Buy Death by Modern Medicine at to educate yourself and anyone you know about Codex, the war on dietary supplements, and what you can do to stop this nonsense. Monies from the sale of this book will go to help fund the health freedom movement.


1. European Supplements Directive Challenged in London Court


3. Stuter L. “Using the Delphi Technique to Achieve Consensus.” The Education Reporter. No. 154. Nov. 1998.
4. “How To Counter Group Manipulation Tactics.” Beverly Eakman at

(Taken from Death by Modern Medicine (March 2005) by Carolyn Dean, MD, ND with Trueman Tuck)

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Written by Carolyn Dean

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