Please refer to anzfa’s guide to applications and proposals for a more detailed explanation of the process on how to undertake

2. Choice of food vehicle for fortification

Those in support of mandatory fortification acknowledged the widespread consumption of bread (or products made from bread-making flour) among the population as a whole, including differing socio-economic groups and the Indigenous population.

Those against mandatory fortification questioned the choice of flour, particularly as a vehicle for women who were gluten intolerant or used alternative staples. Some considered that bread consumption was declining among young women, although there was little good quality data to support this notion. Some submitters noted that 20% of the target group did not consume bread and bread products.
Industry raised specific concerns around the technical difficulties and cost implications of fortifying the proposed food vehicle to the required level (see industry issues below).
Several submissions including food industry called for other food vehicles to be considered or the extension of voluntary permissions to other foods e.g. bread and / or dairy foods.
Some submissions indicated their confusion about the preferred food vehicle e.g. whether it included non-wheat flour and organic flours.

3. Potential benefits and risks of increased folate status

Those in support of mandatory fortification acknowledged the evidence for increased folic acid intake in reducing the incidence of NTDs, in particular the evidence from countries such as the United States and Canada which have implemented mandatory fortification. The proposed approach was recognised as a safe and effective public health intervention; many considered the health risks to be minimal.

Those against mandatory fortification considered that the health benefits and risks were too uncertain, particularly the long term safety, and that the health benefits may be outweighed by the potential health risks. Submitters were concerned about the possible effect of increased folic acid on the non-target population, especially children and the elderly. Some considered that detection of vitamin B₁₂ deficiency remained a concern from increased folic acid intake. Several submissions raised the issue that increased folic acid intake may increase risk of cancer (colorectal, breast) as indicated in recent published papers.

4. Level of fortification

Many submitters (including those for and against the preferred option) considered that the level of fortification (200 µg per 100 g flour) was small and therefore the impact on the number of NTDs prevented was minimal. Those in favour, however, acknowledged the need for a conservative approach particularly in light of recent literature which postulates an association between increased folic acid intake and a potential increased risk of cancer.

Industry considered the level of fortification was too precise and stated that it could not achieve this precision via fortification of flour.

5. Impact of fortification on consumer choice

The lack of consumer choice was a key objection to mandatory fortification and was raised often in submissions. Submitters acknowledged the need for maintaining some form of consumer choice. Several suggested organic foods containing bread-making flour should be exempt.

Those in favour of mandatory fortification generally recognised the importance of consumer choice, but believed that loss of consumer choice was a small imposition compared with the broader public health benefit.
A number of submitters considered the level of folic acid must be included on the Nutrition Information Panel to allow women to calculate their folic acid intake, to allow more informed choice. Some submitters recommended labelling includes dietary folate equivalents (DFEs).
NZ industry and the NZ Government noted the strong opposition to mandatory fortification in two recent New Zealand surveys and considered this had not been adequately addressed by FSANZ.

6. Impact of fortification on industry

Those in support of mandatory fortification believed that the cost to millers to fortify flour with folic acid was small compared with the benefits to society. As thiamin is already added to flour in Australia the technology and methods should be in place.

There was, however, considerable industry opposition to the mandatory fortification proposed approach. Industry concerns included the following issues:

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  significant costs to industry to upgrade capital equipment, and for labelling and packaging;
  
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  the range of folic acid in the proposed food standard is too narrow for industry compliance;
  
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  analytical testing on site will be necessary with attendant huge costs;
  
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  industry/product liability should there be any adverse health effects on consumers;
  
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  loss of competitive advantage associated with voluntary fortification;
  
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  mandated levels will not allow industry to make a folate health claim; and
  
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  the impact on trade of flour fortified with folic aid.
  

Industry considered mandatory fortification could result in a loss of export earnings if assurances about folic acid contamination could not be given and due to the costs of mandatory fortification e.g. labelling. This view was supported by NZ Government. NZ industry noted the presence of folic acid on labels will create barriers to export markets with a consumer preference for unfortified products.

Industry noted the costs involved and time required to make labelling changes. Labelling was also seen as a compliance issue by some industry submitters as they would not be sure whether the flour contained folic acid at the correct level.

Specific New Zealand industry issues included:

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  few mills had the equipment to fortify flour and some smaller mills would not be able to meet the capital expenditure required and would have to close;
  
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  the concept of ‘bread making flour’ is not relevant in New Zealand, as generally mills produce one type of flour; and
  
• 
  monitoring of folic acid in bread would be easily achieved as there are approximately 20 production sites in New Zealand.