The New Zealand Food & Grocery Council notes the Government’s decision today to mandate the addition of folic acid to flour.

Members of FGC have been voluntarily fortifying bread for many years now.

FGC will support its members to meet the Government’s target in 2023. It will be easier to achieve coverage by fortifying bread flour rather than by batches of bread.

However, we are disappointed the Minister for Food Safety refers to FGC’s previous points as “spurious” and “misinformation” when our information presented during the debate some years ago came from some of the world’s most authoritative sources and remains a matter of record on our website.

FGC has always called for all the risks and benefits to the whole population to be taken into account because it’s always a major decision to amend a national food supply.

The information that anchored our position was drawn from two of the world’s most eminent researchers in the subject: University of Oxford University researchers Emeritus Professor David Smith (the Chair and Head of Pharmacology at Oxford from 1984 -2005), and Human Nutrition professor Dr Helga Refsum.

At the time they had around 50 papers on the topic of folic acid and had raised legitimate concerns about blanket mandatory fortification without considering all the risks. The benefits and risks associated with exposing the whole population (men, elderly, children) to increased levels of folic acid are discussed in these papers and reports.

We encouraged Ministry for Primary Industries officials to have direct, expert-to-expert discussions with them but there appeared to be no interest in this.

Prof Smith read and largely supported Professor Gluckman’s report. They had drawn on most of the same papers and conclusions. Where they differed was in their scientific opinions on the potential harms of exposing all non-targets for the fortification with the additive and the absolute numbers of potential cancers.

All other information pointed to by FGC also came from authoritative sources, including New Zealand Food Safety Authority, Food Standards Australia New Zealand, Otago University, and Parliamentary questions, where at the time the Minister for Food Safety estimated the daily intake would require 11 slices of bread.

Our caution has always been based on evidence of concerns about:

• expected and potential over-consumption by non-target population groups, most New Zealanders, and especially children 1 to 8 years old. We were uncomfortable at the level of overconsumption by 5-8-year-olds and very concerned at the prospect of younger children being even more exposed to exceeding the upper allowable limit. This is why we encouraged the Government to consider this before any final decision.
• the interaction of a high folate status and low vitamin B12 with respect to cognitive function
• the impact of unmetabolised folic acid circulating in the blood. Again, our last submission to the Ministry asked that this be considered.

In our submission in 2019 we asked the Government to consider these issues, particularly relating to the overconsumption by children, elderly, men etc. The Government has announced its decision, so has clearly weighed up all potential benefits and all harms taking the whole population into account.

We’ve often made clear our support of folate and its role in nutrition. Folate is an important part of the diet, particularly for women of child-bearing age. However, commentators and government representatives often use folate and folic acid interchangeably when they are similar, but not the same. Folate, a natural B vitamin, is essential for good health. Folic acid (pteroylmonoglutamic acid) is a synthetic and most chemically stable form of folate.

It is accepted folic acid can have both positive and detrimental effects. This point was made in the Royal Society report: “2.2 Cancer The evidence suggests that folate may have both protective and detrimental health effects in relation to cancer, and its ultimate effect depends on both the level of intake (i.e. dose), and the absence or presence of precancerous lesions13 and established tumours (i.e. timing of exposure) [46]. Thus, adequate folate is essential to maintain normal function of healthy cells, but high folate levels may accelerate the growth of pre-existing tumours (Appendix 5.7.5.1).”

There’s another important issue regarding today’s decision.

The data on what New Zealanders eat is wildly out of date. The National Nutrition Survey for children was last completed in 2002, and for adults 2008. Industry, academics, and officials have been united on lobbying for a new survey. Without up-to-date information, the Government runs the risk of flying blind on critical decisions about nutrition and the food supply.

Since fortification campaigns began, folic acid has been added by the food industry to a range of other grocery products, including breakfast cereals and to bread on a voluntary basis. Between 38% - 50% of all bread, including half of packaged bread, is already fortified.

We told the Government it needed advice on how much folic acid was already in the food supply before further intervention. Prof Smith advised that with current fortification rates and blood folate levels in the New Zealand population, further benefits of mandatory fortification were likely to be marginal.

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