A Decision Tree for the Legal Classification of Food Supplements in the European Union Based on an Analysis of RASFF Notifications on Food Traded Online

Abstract The continuous growth of food e-commerce increasingly reveals food safety concerns and public health risks amplified by regulatory and enforcement challenges. Yet, systematic assessment of the associated hazards remains limited. This study characterises food safety hazards in the EU online food market, assesses the extend to which they are addressed by current regulatory frameworks, and identifies gaps that undermine effective risk management. We conducted a secondary analysis of publicly available RASFF notifications related to e-commerce and performed a structured legal classification to determine the regulatory status of hazards associated with food supplements. To enable systematic analysis, we developed a decision tree incorporating international, European and national decision bases. We identified 910 RASFF notifications related to e-commerce submitted between November 2017 and June 2023. These included 786 notifications on food, which were mostly related to the presence of specific substances or ingredients (82.1%) and reported 210 distinct hazards – most commonly 2,4-dinitrophenol, cannabidiol and yohimbine. Food supplements reported in 689 notifications mainly contained “other substances”, notably botanicals. Applying the decision tree, two thirds of the 178 distinct hazards identified in food supplement notifications could be classified using food-related decision bases. Together, these results demonstrate the wide range of hazards in food and especially food supplements traded online and highlight substantial gaps in the European regulatory framework. Based on our findings, we recommend strengthening consumer health protection through more coherent and effective risk management measures for food supplements and propose our decision tree as a practical tool for their evaluation and (automated) monitoring in e-commerce.