"After studying 16,000 pages of the official documents of CODEX ALIMENTARIUS...I am dedicating my life to protecting America from this destroyer of health freedom!"

- Rima A. Laibow, MD

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Open Letter on CODEX (May 23, 2005)

By Rima E. Laibow, M.D., Medical Director of the Natural Solutions Foundation

Dear Reader,

Each of us is deluged daily with so much information that we are forced to choose quickly between what deserves our attention and what to throw in the circular file. This is a long letter with a great deal of detail in it. I implore you to read it because your health freedom and your health, depend on what this letter is about to tell you!

No doubt you have received as many rambling, lengthy, semi-incoherent emails about CODEX ALIMENTARIUS as I have. I have deleted more of them than I can count that were either too alarming or too complacent in nature and simply lacked credibility. Now, let me ask you if you know anyone who has actually read more than 16,000 pages of the working documents of the CODEX ALIMENTARIUS Commission?

Well, I have.

As such, allow me to attempt to put an end to any confusion you may have about CODEX ALIMENTARIUS by sharing what I have learned and what I believe to be a reasonable and appropriate level of concern.

What's the bottom line for a healthcare professional practicing alternative, nutritional, natural, or environmental healthcare? The World Trade Organization (WTO) (and the agreements we signed as part of our membership) stands poised to take away your right to chose health options guided by common sense, science and your personal preferences and choices!

Through the Orwellian process of "HARMonization" (forced alignment) with WTO standards regulating international trade, distribution, and processing of food, herbs, and nutrients, your personal health rights and options would be eliminated within the next few years. Your rights to use whatever type of medicine you choose, whether natural or pharmaceutical, would be eliminated! The proposed standards are extremely detrimental to the environment, your health freedom, your health and your access to clean and unadulterated food.

Okay. I saw that one eyebrow go up and heard that deep sigh. Let me tell you that alarmism is not, and never has been, in my nature. I am a medical doctor, have a wide variety of interests, am passionate about healthcare freedom, and pride myself in my rational thinking and logic skills. I floss my teeth regularly and eat a nutrient-dense whole foods diet and, yes, occasionally sample the more decadent side of the culinary arts. Neither my family nor I had a bomb shelter during the Cold War era and I did not withdraw from society or stock up on gasoline, food, or batteries in anticipation of Y2K. Read on.

CODEX is based neither on science nor democracy. Unelected bureaucrats, operating at the behest of industry and trade interests, not public health, make decisions which become domestic and international standards when enacted as law by the member states of the WTO. These standards represent the ultimate triumph of greed over good science, good sense, good health and good intent. Carolyn Dean, M.D., points out that in 1995, when the WTO was created, the original purpose of CODEX (to provide clean food for the planet with no international barriers to the movement of that food) was replaced by industry interests [1]. The deadly results are clear in what you are about to read.

Your rights to chose natural health options such as therapeutically effective dietary supplements, unadulterated foods with minimal pesticide and toxic residues and other natural treatments are about to be converted into crimes in the United States by a draconian set of international regulations. These regulations, called CODEX ALIMENTARIUS, have already been translated into law (via the European Food Supplements Directive) in the European Union (EU). Through "HARMonization" with CODEX via the Trans-Tasman Agreement, Australia and New Zealand have been "HARMonized" with CODEX and Canada has achieved the same status indirectly by "HARMonizing" with the Trans-Tasman Agreement [2] [3] [4] [5] rather than with CODEX itself. The net result, however, is the same HARM through "HARMonization" with CODEX.

The CODEX ALIMENTARIUS standards, (from the Latin for "Food Rules") are being promulgated by the CODEX ALIMENTARIUS Commission [established as a Trade Commission in 1963 by the United Nations (UN)] concerning every area having to do with the production, processing, packaging and use of food, herbs, supplements and food components.

Think it can't happen here?

Think again. There is a world-wide push for "HARMonization" to eliminate clean food, nutritional supplements, therapeutic vitamins and other natural health choices [6]. It can and it will, unless we, the people of the United States take appropriate action and activate each member in our personal and professional networks. Skillful disinformation would have you believe that CODEX ALIMENTARIUS (hereafter referred to as CODEX) is a hoax and that, at the same time, it is beneficial for you and your patients. The inherent illogic of this position is obvious to the discerning reader [7] [8] [9] [10].

We hardly need to be protected from safe and effective natural healing tools. Instead, pharmaceuticals, the third largest killer in America WHEN PROPERLY USED [11], would be our only options. CODEX ALIMENTARIUS is the triumph of pharmaceutical greed: when our food has been poisoned and we and our children are dying in huge numbers of the diseases of toxicity and undernutrition, will pharmaceutical medicine help then?

Natural medicine remains the best prevention, treatment and cure for chronic disease. CODEX eliminates that option.

The CODEX ALIMENTARIUS Commission was empowered to work with other UN-linked organizations in order to develop and promulgate uniform world-wide standards for food, nutrition and agriculture. The WTO, successor to the General Agreement on Tariffs and Trade (GATT), is empowered to enforce global compliance with all CODEX standards via trade sanctions across the entire economic spectrum. Member nations (read "the United States") agreed, upon signing the WTO treaty, to always allow the standards and regulations of the WTO to supersede (take precedence over) national standards, laws, and regulations.

Despite what you may hear to the contrary, because of the Sanitary and Phytosanitary Agreement (SPSA) [12] , once accepted, CODEX guidelines and regulations take on the force of law in each member nation of the WTO - and that includes the U.S. and cannot be repealed or changed by the WTO member nations. This means that once the U.S. is "HARMonized" [13] with CODEX, despite what you are being told, the Dietary Supplements Health Education Act (DSHEA), 1994, no longer governs the U.S. position on nutrients: CODEX does!

Presenting itself as a consumer protection strategy, CODEX policies masquerade as benign and beneficial while, in reality, they are neither. Given the medically and environmentally horrific stipulations and requirements of CODEX, the implementation of these "standards" would result in incalculable harm to the healing arts and to the patients who depend on them.

Once CODEX is adopted by a nation via "HARMonization" (forced acceptance) or through the effects of the SPSA, there is a "phase-in period" during which the administrative structure of implementation is established according to a strict time-table. Bear in mind that in the United States, nutrients are currently classified as foods and so have no upper limits [under the 1994 Dietary Supplements Health and Education Act (DSHEA)] and that any substance not explicitly forbidden is permitted as a nutrient in the United States. Under CODEX, any substance and any dosage not explicitly permitted by CODEX policy is banned as a nutrient. The difference is of major importance to Health Freedom. DHSEA is good for health freedom. CODEX is bad (very bad) for health freedom.

CODEX eliminates the possibility that supplements and nutrients may be used to prevent, treat or cure any disorder [14]. In fact, the EU observer of the CODEX Committee on Nutrition and Foods for Special Dietary Uses (CNFSDU) stated in the CODEX ALIMENTARIUS Commission meeting, 2003, that "food and the prevention of diseases do not go together." He was supported by the Chairman of CNFSDU, who said that drugs are to mitigate and prevent diseases, and that the role of food supplements is to support the diet [15].

Yet, more than 80 percent of Americans use supplements specifically to prevent, treat and cure diseases and conditions. Nutritional and environmental physicians, naturopaths, nutritionists, chiropractors and other licensed health professionals employ hundreds of natural minerals, supplements, and herbs precisely because they are effective in preventing, treating and curing many diseases and chronic, degenerative conditions.

Consumers make choices in natural health to the tune of $20 Billion per year in the United States for supplements alone. Do we really want a democratically unaccountable trade organization to tell us that we cannot make those choices any longer?

Dr. Wong Ang Peng, who was present at the November, 2003 CODEX Committee on Nutrition and Food for Special Dietary Uses (CCNFSDU), wrote:

"We, the people of the world have entrusted WHO, FAO, and CODEX ALIMENTARIUS to regulate on health measures, to protect our health. If only the people knew.... CODEX is not about health, it is about wealth. CODEX is not for public interest, it is for industrial interest. It was super sold out. It was super hypocrisy." [16] [emphasis added].

Natural health options, starting with therapeutically effective vitamins, minerals and nutrients would become illegal in the U.S.:

  1. If the United States is "HARMonized" with CODEX ALIMENTARIUS this spring/summer while compliance with CODEX is still "voluntary," or
  2. When compliance with CODEX becomes mandatory if the Vitamin and Mineral Standard is ratified as expected at the next CODEX ALIMENTARIUS Commission meeting, Rome, July 4-9, 2005. Other nutrients would quickly follow into oblivion according to the stated intentions of the EU delegate and CNFSDU chairman at that same meeting [17].

If the European Food Supplements Directive (EFSD) is any guide (and it has been described by the Chairman of the Committee on Nutrients and Food for Special Dietary Uses (CCNFSDU), Rolf Grossklaus, M.D., as "the future face of CODEX"), nutrients, inappropriately classified as toxic chemicals, are permitted only at dosages

  1. No higher than that found in food and
  2. So low as to have no biological effect on even the most sensitive human being.

That is the consequence of using "risk assessment" science, designed for toxic substances, to determine nutrient levels. Nutrients are non-toxic, are foods and thus have no safe upper limits, unlike dangerous industrial and natural chemicals and substances [18].

Health food stores would no longer be able to market and distribute nutritional supplements at therapeutic doses. Most health food stores and privately owned nutrient manufacturers would, I believe, no longer be in business if CODEX takes effect.

I know. This is all difficult to believe upon first hearing. You may have heard that it is easy to get people to believe a lie, particularly an outrageous lie. In my experience, the opposite is also true: It is even more difficult to get people to believe an absolutely insane and outrageous truth. Keep on reading, because this is a truth you definitely need to understand.

Once CODEX is implemented (either through "HARMonization" or mandatory compliance), we would be forced to follow something very close to the European implementation model of CODEX under which it would be illegal to manufacture, buy, sell, recommend, or use any but the EFSD's 28 ultra-low dose nutrients (including Fluoride, a systemic poison, by the way!) whether you are a licensed health professional or not [19]. Natural supplements at therapeutic doses, herbs, enzymes and other non-pharmaceutical treatments would be banned. The only legal health options left would be the pharmaceutical one (of course, surgery and radiation would still be available, too).

CODEX regulations have been "HARMonized" (i.e., approved) and/or are scheduled for implementation in the EU, Canada, New Zealand and Australia as well as the entire Asian Pacific Region (via the Trans-Tasman Agreement explained above). The United States is next unless we act decisively! Remember, although CODEX regulations are passed quietly and without effective public notice through infrequent meetings abroad that are invisible to most Americans, they would have grave and devastating impact on America's health freedom.

Here in the United States, the "HARMonization" laws which would enact CODEX policy have been defeated by Congress several times, each time by a smaller margin [20]. Given the composition of the current Congress, it is virtually certain that "HARMonization" legislation would be passed when introduced unless we take swift and immediate steps to assure that does not happen. Through this web site, we have made it easy for you to take action in 6 steps!

This legislative "stealth attack" on health freedoms will probably play out in May or early June of 2005 unless we assure that Health Freedom becomes the "Mother of All Third Rails" for every politician in the country. Here's how a third rail works: touch it and so much energy runs through your body that you are instantly dead. For a politician, that means instantly un-re-electable!

It is vitally important when thinking about CODEX to remember that CODEX is not a democratic process and we, the people, have neither voice nor vote in the matter. Run by unelected bureaucrats, primarily from the FDA here in the U.S., CODEX is the result of a complex relationship between the UN (which established the CODEX ALIMENTARIUS Commission in 1963); the WTO (which is authorized to enforce CODEX through trade sanctions); the World Health Organization (WHO),which subscribes to the CODEX regulations [despite the fact that they directly and explicitly conflict with their own findings and policies such as the FAO/WHO official publication, "Diet, Nutrition and the Prevention of Chronic Diseases"]; the Food and Agriculture Organization (FAO), the United States Food and Drug Administration (FDA); and the United States Department of Agriculture (USDA) working in concert with industry representatives of (and others unofficially representing the interests of) the pesticide, chemical, pharmaceutical, and dairy industries. All of this is carried into domestic law by the nearly unknown Sanitary and Phytosanitary Agreement (SPSA) [21].

Consumers, health scientists, physicians practicing natural medicine and other health-focused voices have been absent from official CODEX deliberations. Representatives of the newly "pharmaceuticalized" natural health industry (e.g., IADSA, NNFA, CRN) have attended but their position supports the adoption of CODEX standards because it would open new international markets for them and increase their profits by allowing them to sell clinically ineffective mini-dose nutrients at exorbitant prices. A few observers with interest in the natural health arena have been present at official deliberations but they have not been permitted to speak in the sessions. A very small number of International Non Governmental Organizations with health freedom interests have been permitted to attend and may speak but they may not vote.

Full ratification of the desperately wrongheaded CODEX ALIMENTARIUS Vitamin and Mineral Standards is expected in Rome during the July 4-9, 2005 meeting of the CODEX ALIMENTARIUS Committee.

Of course, the real work of such a complex regulatory structure takes place outside of those official sessions. And natural health advocates do not have access to those meetings, agreements and sessions. Yet CODEX would take away our health freedoms if we allow ourselves to be "HARMonized" or mandated to comply with it.

Everyone knows if they have a jar of pickles and they remove the pickle label and put a mayonnaise label on it, that they're going to find pickles when they open the jar. The packaging of CODEX policy under the label of protection of fair trade, public health, and safety does not make it so. Underneath CODEX's altruistic labeling is a poisoned apple of extremely adverse global policy that is, in fact, driven by economic concerns of large corporate interests.

CODEX ALIMENTARIUS is far more than a mindless restriction on nutrients, however. Once implemented, CODEX ALIMENTARIUS would do the following:


  1. CODEX prohibits the use of nutrients to "prevent, treat or cure any condition or disease".
  2. CODEX defines minimum allowable dosages of permitted nutrients as 15 percent of the amount naturally occurring in foods, while maximum allowable doses of any permitted nutrients may not exceed the dose of that nutrient found in food! Permitted nutritional supplement values subtract the amount assumed to be in the average expectable daily diet [22] from the maximum allowable dose and the result is the permitted upper limit of a nutrient. No dosage of this nutrient may be used which is any higher than the permitted upper limit with or without a prescription. This system is based neither in science nor sense.
  3. Higher doses of permitted nutrients and other nutrients not explicitly permitted would be classified as illegal substances (like heroin) and, as such, would be legally unavailable under any circumstances. The system for testing additional nutrients or higher nutrient doses exist but is a total sham:
    1. Theoretical exceptions exist for natural substances which are submitted and accepted for testing by July 12, 2005 at a cost of approximately $250,000 per submission.
    2. If accepted, a substance may undergo Phase 1, 2 and 3 testing as a drug.
    3. If, after testing, the substance is found to be efficacious and safe, it may be marketed as a prescription drug.
    4. Permission to market as a drug expires on December 31, 2004 and cannot be renewed or extended.
    5. A substance successfully tested in this way may then be prescribed at the tested dosage only and for the tested conditions only.
    6. The cost of this procedure is staggering, most applications for such testing have been turned down and, since natural molecules cannot be patented, potential manufacturers are unable to recoup the outrageous costs of testing through later sales.
  4. The European Union (EU), whose Directives (e.g., EFSD and the ETHMPD) are the model administrative agencies for CODEX implementation, permits a total of 28 ultra-low dose nutrients as of August 1, 2005. Nutrients like Boron, Vanadium, and Natural (Mixed Tocopherol) Vitamin E, for example, are banned under the EFSD. CODEX is expected to follow suit this July through ratification.

    All other nutrients (e.g., alpha lipoic acid, glutathione, picnoginol, 7-Keto DHEA, 1 gram doses of vitamin C, Co Q 10, fish oil, and curcumin, etc.), while not explicitly covered by the July guideline, are anticipated to become banned substances as the anti-therapeutic nutrients stance of CODEX is made final in the coming 5 years before full implementation of CODEX ALIMENTARIUS on January 1, 2010.

    The CCNFSDU has made it clear that other nutrients, would be excluded under the positive list/negative list concept under which:

    1. everything not permitted on the positive list is forbidden and
    2. everything forbidden on the negative list is forbidden by virtue of being absent from the positive list.

    According to Paul Anthony Taylor, present at the Bonn 2004 CCNFSDU meeting,

    "During the discussions on Scope, the Chairman inferred that the EU wanted to leave the door open for the Draft Guidelines on Vitamins and Minerals to be extended to other nutrients. The EC Observer replied by saying that they did not want this, but that if the Scope was defined too rigidly some products might be taken out of the Guidelines by the addition of other nutrients, thus claiming that they were not vitamin and mineral supplements. As a result of this, the Committee added the following sentence to the Guidelines: Food Supplements containing vitamins and/or minerals as well as other ingredients should also be in conformity with the specific rules on vitamins and minerals laid down in these Guidelines. [emphasis added]" [23]

    These forbidden substances, essential and vital nutrients in therapeutic dosages, would be legally forbidden and, as such, may not be manufactured, distributed, recommended, sold, supplied or be in the possession of anyone, including licensed health professionals. Vitamin C, for example, at any dosage higher than 200 mg per day would be illegal. A gram of Vitamin C would be an illegal substance under CODEX! The dose of Co Q 10 which has been shown to resolve breast cancer in some patients (400 mg per day) [24] would be illegal because, if CODEX proceeds as its Nutritional Supplements Committee Chairman, Dr. Grossklaus has indicted it would, "nutrition has no place in medicine" and nutrients, therefore, also have no place in medicine according to Grossklaus. Think about it.

  5. The allowable maximum upper limits for permitted nutrients have intentionally been set so low that they have little or no clinical impact on any human being, no matter how sensitive to the nutrient! This is the "gift" of "Risk Assessment Science" to nutritional medicine. By the way, the only company permitted to submit risk assessment data to CODEX, the BfR, is owned by Dr. Rolf Grossklaus, the chairman of CCNFSDU! So according to CODEX, nutrients have no role in keeping us healthy and none at all in returning us to a state of health if we are ill. Those ultra low dose nutrients which are available should CODEX be implemented will be exorbitantly priced, as current experience in Norway and Germany reveals, where profit margins of synthetic, permitted nutrients are being "HARMonized" to match drug profit margins.

    1. On August 1, 2005, 75 percent of the natural substances currently available in health food stores and pharmacies in Europe are set to become illegal as a direct result of CODEX via the EFSD.
    2. A non-binding opinion of the Judge Advocate General of the European Court of Justice (ECJ) rendered on April 5, 2005, required the EFSD to use more science to create its standards. The rest of CODEX implementation, however, was not challenged. This opinion has no legal weight and the ECJ is expected to render its final ruling in June, 2005. If the EFSD is upheld, the August 1 ban will go forward [25]. If it is not, it will be revised and then go forward.
    3. Even if the EFSD guidelines are overturned, member nations of the WTO (that means the U.S.) are bound by the SPSA to bring their standards into conformity with CODEX guidelines and standards.

  6. Although CODEX's current Vitamin and Mineral Standard (not yet ratified) states that natural and synthetic forms may be used, under the EFSD, only synthetic forms of permitted nutrients would be available. Under the EFSD, natural versions would become illegal substances. Only synthetic nutrients (at ultra-low dosages) manufactured by pharmaceutical companies would meet the CODEX-determined molecular standards for use in humans or animals. As he repeatedly states, Dr. Grossklaus maintains that the EFDS is the future face of CODEX ALIMENTARIUS.
  7. While the problem here in the United States is acute, it is a problem of crisis proportions in the underdeveloped world. According to the UNESCO Report, Vitamin and Mineral Deficiencies: A Global Progress Report,
    "Few outside specialist circles are aware of the scale and severity of vitamin and mineral deficiency, or of what it means for individuals and for nations. It means the impairment of hundreds of millions of growing minds and the lowering of national IQs.

    It means wholesale damage to immune systems, and the deaths of more than a million children a year. It means 250,000 serious birth defects annually and the deaths of approximately 50,000 young women a year during pregnancy and childbirth.

    And it means the large-scale loss of national energies, intellects, productivity, and growth.

    This problem was largely controlled decades ago in the industrialized [sic] nations. It could now be controlled world-wide by means that are tried and tested, available and affordable. That is why the World Bank says that "The control of vitamin and mineral deficiencies is one of the most extraordinary development-related scientific advances of recent years. Probably no other technology available today offers as large an opportunity to improve lives and accelerate development at such low cost and in such a short time". [26]


  1. According to a British report on Celebrity opposition to the EU herbal ban,
    "The Traditional Herbal Medicinal Products Directive [THMPD], due to come into law no earlier than 2003/4, states a product can only continue to be sold if it has already been on the market for 30 years, including 15 in Europe. Some 300 nutrients and nutrient sources already on sale in the UK are not on the permitted list and, unless comprehensive safety dossiers are approved or the remedies are licensed in the same way as pharmaceutical drugs, would be banned. Products affected include Vitamin B6, Vitamin C, Echinacea, Black Cohosh, St John's Wort, Multi- Vitamins and Minerals." [27]

  2. Herbs, originally part of the CODEX deliberations, were summarily removed and placed under a closed committee of the WHO where they are anticipated to be classified as untested drugs and then classified as illegal substances. Once this recommendation is made to the CODEX ALIMENTARIUS Commission, probably just before global implementation of CODEX on January 1, 2010, it is anticipated that it would be followed according to the legal analysis of experts in this matter.
  3. The European THMPD, part of the European model implementation system for CODEX, has produced a very short list of herbs which may be used and the conditions for which they may be used (another short and very trivial list) while any condition which might require "medical", (i.e., pharmaceutical) care may not be treated with herbs. [28] [29]
  4. All other applications of herbs and any other herbs besides those permitted are strictly forbidden since they and their indications are not on the "positive list".
  5. There is the possibility that a few formulas of well known Chinese or other traditional herbal medicines may be exempt (but that remains to be seen).


  1. Ayurveda, Tibetan, tribal and other traditional medicines which use herbs and natural substances would be forbidden world-wide since efficacy and scientific documentation is hard to come by in these healing arts. Since most people do not have access to pharmaceutical medicine, this effectively removes the legal possibility of people accessing any form of tribal or traditional medicine without committing a crime against the country in which they live.
  2. The ETHMPD actively discriminates against herbal medicine. According to Sepp Hasslberger,
    "While the directive was necessary to "salvage" a large number of registered natural medicines that existed on the German market, and which had to be terminated by the end of this year because they could not fulfill the criteria for full medicines registration, it does discriminate against herbal medicines from other traditions, such as Chinese Traditional Medicine and Ayurvedic [sic] medicinal herbs, by requiring traditional use in Europe as a pre-condition to registration. Such non-EU traditional herbal medicines could in theory obtain a full medicine registration, but in practice there are unsurmountable [sic] barriers in the full medicine registration requirements, which are clearly slanted to favour [sic] the patentable chemical remedies of pharmaceutical manufacture. By excluding other herbal traditions, the European herbal medicines directive seems to be at odds with an initiative of the World Health Organisation [sic] which has recently issued guidelines for the safe use of traditional, complementary and alternative medicines including herbals, which the UN body wishes to be widely available in all countries as an alternative to pharmaceutical medicines." [30]
  3. South Africa and India have repeatedly expressed their dissatisfaction with "foods as drugs" and the restriction of nutrients and herbs but have been regularly overrun by "consensus" tactics which do not allow full discussion or debate on these crucial issues [31].


  1. CODEX makes the un-labeled use of GMOs legal globally, even though there is significant science-based opposition to the widespread use of GMOs because of their untested impact on human health. Although there are standards for testing of GMOs incorporated into CODEX.

  2. The CODEX Committee on Nutrients and Foods for Special Dietary Uses allows GMOs in baby foods and formulas. Dr. Wong Ang Peng, wrote of the 2004 Bonn CCNFSDU meeting, which he attended,
    "Sadly too, the proposal of EU to allow GMO (genetically modified organism) ingredients in infant formulas did not get much opposition, except from a public interest NGO. GMO ingredients, the domains of multinational corporations from the developed countries, would from now be openly allowed into baby food. Let it be on record that the delegates of this 25th Session of CODEX Committee proposed and approved these patented, DNA mutating junk ingredients." [32]
  3. GMO organisms are far from safe. Many GMOs have been genetically engineered so that seeds WOULD NOT GERMINATE without the use of specific pesticides [33] (such as Roundup™ by Monsanto®). In fact, mounting scientific evidence makes it clear that the incidence of cancer, ALS, Parkinson's Disease, birth defects, chemical sensitivity, chronic fatigue syndrome, asthma, severe allergies, and a host of other serious, previously rare, increasingly common and deadly conditions have a causative or contributory relationship with increasing levels of pesticide exposure that these crops require. GMOs themselves are far from scientifically established as safe for either the planet or its people by objective, non-industry scientists. In addition to the human health dangers of GMOs, genetic drift and contamination through the spread of GMO genetic material is recognized as a major threat to the biological integrity of the entire planet.
  4. GMOs may be freely used in animal feed without being labeled.


  1. CODEX sets permissible upper limits for pesticide and veterinary drug residues, toxic chemicals, hormones in food and other environmental contaminants many times higher than levels advocated by even chemical and pesticide industry lobbying groups [34] [35].

    For example, aflatoxin, the second most potent non-ionizing carcinogen known, is permitted by CODEX at frighteningly high levels in milk, consumed in large quantities by children. The WHO conceded in a press release that these levels were very high, stating, "The CODEX Commission also set maximum levels of aflatoxin in milk and milk products. Aflatoxin is a carcinogenic substance that can be transmitted from animal feed (for examples, peanuts and corn) into milk. The new maximum limit for aflatoxin in milk is 0.5 micrograms per kilogram.

    Some countries argued for a stricter aflatoxin limit of 0.05 micrograms per kilogram. However the majority of countries agreed that the higher limit was more feasible, particularly in developing countries." [36]

  2. Current "acceptable" levels of toxins are already responsible for most of the incidence of cancers, heart disease, autism, chronic degenerative conditions, and organ failures associated with mortality and morbidity globally. Cancer, once a rare occurrence, is anticipated to strike 50% of the earth's inhabitants by 2010 under current permissible levels of pesticides and other toxins! When CODEX institutes its much higher "Safe Upper Limits" for these substances, the impact on the collective immune system and fertility rates of the planet are beyond imagining. Increasing the permissible levels of toxins can only accelerate personal and global suffering and death [37].


  1. CODEX mandates that all conventionally farmed livestock be treated with antibiotics, veterinary drugs, hormones and growth stimulants
  2. Vague, imprecise and unenforceable CODEX "guidelines" exist to "prevent irresponsible use of veterinary drugs " [38]. These loose guide lines are in sharp contrast to the minutely controlled and detailed prohibition of nutritional standards, with a sharply defined positive list and a broad explicit and implicit negative list, which effectively prohibits all therapeutic dosages of all nutrients. Clearly, veterinary drugs are allowed without limit or penalty if they are overused, no matter how harmful they are to both livestock and humans while nutrients at any significant dose are forbidden, no matter how safe and essential.
  3. Organic, free range and biodynamic farming, while technically permitted, is defined so loosely that antibiotics, toxins like Rotenone, fish and dairy products for livestock feed and veterinary drugs (including antimicrobials) may be used at the discretion of the certifying agent or farmer. Drought, hardship, severe conditions or "other" situations can all cause the definition of "organic" to be stretched beyond reason and safety. There are no penalties for violation of "organic" farming principles for either crops or animals.
  4. Even the most positive gloss on the organic standards makes it clear that the CODEX standard is appalling loose:
    "The CODEX meeting also agreed to new guidelines for organic livestock production. According to these guidelines, organic livestock farming should aim [emphasis added] to use natural breeding methods, minimize stress in animals, prevent disease, and progressively eliminate the use of certain chemical veterinary drugs, including antibiotics [emphasis added]. Animals should mainly be fed with high quality organic feed [emphasis added], not meat and bone meal, although fish and milk products are acceptable. The use of growth hormones is not permitted." [39] [40]
  5. The most casual examination of the standards and definitions of "organic food" (meaning as little as 70% organic contents without informative labeling to that effect), the chemical standards for animal feed and treatment, the short "conversion times" to move animals, fields and crops from conventional to "organic" and the permitted use of chemicals and toxins in the production of crops and animals makes it clear that this standard is nothing more than window dressing for a toxic food supply [41].


  1. In the summer of 2003,
    "CODEX weakened the international food irradiation rule to allow any food to be irradiated at any dose, regardless of how high. The new Standard contains no maximum radiation dose to which foods can be treated. The previous limit was 10 kilo Gray, a dose of radiation equivalent to 330 million chest X-rays. At such doses, the chemical composition of foods can be altered; vitamins, proteins and other nutrients can be destroyed; and flavor, odor and texture can be corrupted. The decision was made over the objections of more than 10 countries, including Austria, Denmark, Germany, Italy, Mexico and Spain. Both the UN and the WHO are mandated to protect the health and welfare of the worlds [sic] population, but they obviously shirked on this responsibility when the decision was made." [42]

    Public Citizen goes on to say,

    "in an October 2002 report by Public Citizen, Bad Taste: The Disturbing Truth About the World Health Organisations [sic] Endorsement of Food Irradiation, the WHO has relied on a very small number of faulty studies in declaring food irradiation safe; this unscientific and shoddy work is the foundation of acceptance of food irradiation across the world. The IAEA owes its loyalty to the nuclear industry and thus works with governments to apply nuclear technologies. It is impossible for the main advocate of nuclear technology to advise CODEX in a disinterested, scientific manner because of its vested interests in the speedy and complete adoption of food irradiation.

    CODEX has not relied on disciplined, dispassionate or scientific advice in setting standards for food irradiation. Instead, the decisions and regulations recommended by CODEX are used as a starting point for the facilitation of international trade. Both the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS) of the World Trade Organization (WTO) and the Agreement on Technical Barriers to Trade (TBT) follow Codexs [sic] lead and encourage the international harmonization of food standards from a trade perspective [43]."

  2. The irradiation of food produces huge free radical populations in that food. The higher the ionizing dose, the higher the free radical population. Under CODEX, food components may be irradiated and then, as they are combined with other components, they may be irradiated again. And again, and again! Each time, the free radical population is increased. The only protection against their pervasive damage is high doses of anti-oxidants like vitamin C, Beta Carotene, Glutathione, etc. (which would be illegal under CODEX, see discussion above).

At this point it will likely come as no surprise to you that there has been no effective representation from health advocates, nutritional supplement manufacturers, natural healthcare professionals, or other non-pharmaceutically oriented group at the CODEX ALIMENTARIUS Commission meeting. The CODEX ALIMENTARIUS Commission meets every two years, always offshore (Rome, Bonn, Paris, etc.) and never in Smallville, U.S.A., a fact that helps perpetuate its opacity to the United States citizenry. The United States' representatives to the CODEX ALIMENTARIUS Commission have well-documented, unwholesome conflicts of interest with the very industries that stand to profit and benefit from the wholesale implementation of the CODEX standards.

CODEX sets international standards for everything from parmesan cheese to sweet cassava, canned sardines to chicken meat, Echinacea to rice. Each standard is ratified after reaching "Step 8" in Committee. Final ratification of the Vitamin and Mineral Guideline is expected at the CODEX ALIMENTARIUS Committee meeting in Rome from July 4-9, 2005.

Before ratification, "HARMonization" is "voluntary" but can be enforced by WTO trade sanctions. After ratification, compliance with CODEX is mandatory and enforcement by WTO trade sanctions is a powerful threat on its own to make sure that it is complied with properly. If that were not bad enough, the SPSA MANDATES domestic compliance with ratified standards. That means that the U.S. must bring its laws and standards down to those of CODEX and keep them there!

So the U.S. can kiss DSHEA goodbye if we fail to act now. Read on and I'll tell you what we need to do to keep the U.S. CODEX-free!

It is imperative that concerned natural health consumers (and their patients, friends, relatives, suppliers, people who shop in health food stores and use clean food and therapeutic doses of nutritional supplements, etc.), become fully activated to stop CODEX from being enacted in the United States.

Now that we know more about the foundering boat in which we are adrift, let me hand you a paddle.

What You Can Do About CODEX!

Become active in the protection of America from CODEX through this web site! If you do nothing now and CODEX is ratified, you will have no environmental or nutritional medical choices. It is imperative that you alert your neighbors, colleagues, friends, patients, relatives, suppliers and everyone else you know to this danger so they can join you in taking effective action. Follow the link above for 6 Easy Steps to protecting America from CODEX.

This threat to our health and health freedom to choose the type of healthcare for our selves and our patients demands one of the most powerful tools available to us: grass-roots political action driven by the communication power of the Internet. CODEX is anything but democratic. We, the American people, however, can use the Democratic Process to our advantage by following the 6 Easy Steps to Protecting America from CODEX. These five steps are easily accessible on this web site, and allow you to do the following five things from the comfort of your computer chair:

  1. Email your Congressional Delegation - We need hundreds of thousands of letters to reach Congress before the July 4, 2005 start of the CODEX ALIMENTARIUS Commission meeting. Our web site features a tool that allows you to find your local Congress men and women, and email them directly. We even have a letter already drafted that you can use - all you have to do is add your name and address.
  2. Sign the Declaration of Health Independence - this is a legal protest to CODEX that I have drafted and which all Americans are invited to add their names to. You send us your name and zip code and then we will print this digital signature on hemp paper and present the Declaration to Congress, in person. We are aiming for over 50,000 signatures!
  3. Join our Citizen's Petition - U.S. law prevents our government from "HARMonizing" with any International Standard which violates U.S. law. We are reminding the U.S. government to honor its own laws with our Citizen's Petition, and you are welcome to add your name to the petition.
  4. Spread the word - as part of step 3, you will be presented with a tool to email this web site to your friends. Through word-of-mouth marketing, we hope millions of Americans will find out about this web site and each in turn take action on the 6 steps.
  5. Subscribe to the CODEX Action Alert - This is the email mailing list of the HealthFreedomUSA campaign. You will receive the latest information on CODEX through your free subscription. It is important that you subscribe so that if we need emergency mobilization (such as extra faxes), then we can call on you to help out.
  6. Support Natural Solutions Foundation's Mission to Reach Millions - National Solutions Foundation is a non-profit Nevada Corporation (of which I am the Medical Director) to preserve, protect and defend health freedom in the United States. NFA is behind the HealthFreedomUSA campaign to raise awareness about CODEX. Our public awareness campaign will cost about $500,000. Without public awareness, CODEX would become our domestic law! Donations help us raise the money needed to raise the public awareness needed. In addition to our Internet marketing activities, the Natural Solutions Foundation has commissioned a major documentary to tell the story of CODEX to the American public. Our only source of funding is voluntary donations by people like yourself.

Here is the golden link to the "6 Easy Steps to Protecting America from CODEX":

It is critical that you and your family, friend and colleagues all take action on these steps. If enough Americans carry out the 6 steps, Congress will not dare allow CODEX to hit the United States of America.

We would all like to put our heads in the sand and try to believe that CODEX would, could and should not happen here. But it can and, unless we take action now, CODEX would become the law of our land.

Whether your motivation is global or local, professional or personal, I urge you to take action now!

With this web site and the "6 Easy Steps to Protecting America from CODEX", we have made it easy for you. Join HealthFreedomUSA and let's each do our part to keep CODEX out of America.

Yours in Health and Freedom,

Rima E. Laibow, M.D.
Medical Director
Natural Solutions Foundation

Read Dr. Laibow's Daily CODEX Update Blog

[1] "CODEX Overview and Report on Bonn, 2004", Carolyn Dean, M.D. in Death By Modern Medicine

[2] Final%20Tokyo%20declaration%20.pdf

[3] 2003/12/05/australian_supplement_laws_for_new_zealand.htm

[4] sepp/2003/12/05/australian_supplement_laws_for_new_zealand.htm

[5] "The Australian Government has signed an international treaty (known as the JTA Treaty) in 2003 which forms the basis for a massive new international regulating "agency". This is due to come into effect July 1, 2005. This new regulating agency, called the Trans-Tasman Agency is structurally nothing more than an off shore corporation partnered by the TGA and multi national drug corporations. That means multi-national drug companies will 'regulate' all vitamins and supplements."
The new 'offshore' agency will operate directly within the international jurisdiction of CODEX."


[7] See, for example, the urban legend site, article "Vitamin See" which promulgates factually inaccurate disinformation about the real nature and impact of CODEX

[8] FDA's Response to Questions page,



[11] Lazarou J, Pomeranz B, Corey P. Incidence of adverse drug reactions in hospitalized patients. JAMA. 1998; 279:1200-1205

[12] Sanitary and Phytosanitary Agreement,

[13] "Harmonized" is the official, Orwellian term for regulatory and/or legislative forced compliance with the guidelines and standards of CODEX ALIMENTARIUS. Note: guidelines and standards have become indistinguishable and now carry the same weight.


[15] Paul Anthony Taylor, personal report, as reported in CODEX COMMITTEE ON NUTRITION AND FOODS FOR SPECIAL DIETARY USES Twenty-fifth Session. Bruckenforum, Bonn, Germany, 3-7 November 2003. A report on the CODEX discussions regarding the Proposed Draft Guidelines for Vitamin and Mineral Supplements, codex_2003_grossklaus_and_mathioudakis_nutrition_not_relevant_to_health.htm

[16] President, Society of Natural Health, Director, The humanitarian Project - Health For All, Tel : 603-20941335, Address : No. 8-5, Jalan Batai, Damansara Heights, 50490 Kuala Lumpur,Malaysia. 2003/11/25/codex_2003_grossklaus_and_mathioudakis _nutrition_not_relevant_to_health.htm

[17] Paul Anthony Taylor, op. cit.

[18] See USLs to Maximum levels: why risk assessment urgently needs review at

[19] Since neither the "positive" nor "negative" lists have been promulgated by the CCNFSDU, the exact contents of that list are not known. Dr. Grossklaus' positions and leadership, however, make it likely that if the lists are not identical to those of the EFSD, they will be nearly so.

[20] For example, a "Harmonization" amendment was lobbied out of the Kennedy Kessembaum Act, 1998,

[21] Sanitary and Phytosanitary Agreement,

[22] This is a completely meaningless concept: do the inhabitants of, say, Tanzania and Greenland have comparable diets and comparable genetic requirements and vulnerabilities?

[23] A report on the CODEX discussions regarding the Proposed Draft Guidelines for Vitamin and Mineral Supplements, prepared by Paul Anthony Taylor. Monday 3rd November 2003, codex_2003_grossklaus_and_mathioudakis _nutrition_not_relevant_to_health.htm

[24] See, for example,

[25] For a positive interpretation of the impact of this opinion, see



[28] Permitted Indications Under the Directive on Traditional Medicinal Products, Annex 1 and 2,

[29] Herbs are seen as a major problem for "HARMonization" in the EU. The European market for herbs and phytomedicines is characterized by the availability of a fairly large number of products. A report conducted in 1991 of the Member States (nations) indicated that about 1,400 herbal drugs were available in the EEC. When this study focused on herbs used in five of the 10 Member States, 145 herbal drugs were noted (Keller, 1996). According to Dr. Konstantin Keller of the German Federal Institute for Drugs and Medical Devices (BfArM), "this shows that herbal drugs are indeed a major problem for harmonization in the EU." (Keller, 1996),

[30] european_directive_on_medicinal_herbs_discriminates_ against_china_india_other_cultures.htm

[31] CODEX Overview and Report on Bonn, 2004, Carolyn Dean, M.D. in Death By Modern Medicine, op. cit.

[32] Dr. Wong Ang Peng, op. cit.

[33] Environmental Medicine uses the term "pesticides" to refer to herbicides, pesticides and toxic agricultural and environmental chemicals of man-made origin. This usage is followed here.

[34] Pesticide Residues in Food, jsp/pest_q-e.jsp?language=EN&version=ext&hasbulk=0

[35] Veterinary Drug Residues in Food, /jsp/vetd_q-e.jsp?language=EN&version=ext&hasbulk=0

[36] WHO Press Release,

[37] See, among many, the Breast Cancer Fund, Report Details New Links Between Environmental Toxicants and Breast Cancer, Oct. 7, 2004

[38] Recommend International Code of Practice for Control of the Use of Veterinary Drugs,

[39] WHO Press Release, op. cit.

[40] Organically Produced Food, CODEX ALIMENTARIUS Document CXG_032e.pdf

[41] Organically Produced Food, passim, op. cit.

[42] Public Citizen Denounces CODEX's Pro Irradiation Stance,

[43] Public Citizen Denounces CODEX's Pro Irradiation Stance, op. cit.


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