fortifying a significant proportion of a range of breads (e.g. light grain breads) identified by consumer research as most popular with the target group. NZAB will assist with funding of this research
fortifying a significant proportion of a range of breads (e.g. light grain breads) identified by consumer research as most popular with the target group. NZAB will assist with funding of this research;
fortification at the bakery with the addition of a specific ‘folic acid mix’ at the same time as bread improvers, as is currently used by George Weston Foods;
include a selection of ‘house-brand’ breads in order to capture price conscious consumers; and
actively promote an education campaign with government funding and industry support.
Consider benefits of the alternative proposal include:
consumer choice is maintained;
a relatively small cost to industry therefore costs passed on to consumers likely to be insignificant;
consumers outside the target group will avoid possible risk from excessive levels;
compliance is relatively easy to monitor by ensuring major plant baking companies are fortifying the agreed number of breads in the selected range, and that key producers of pre-mix and frozen doughs were covered;
an increased ability to control dosage levels, and to avoid potential compliance issues arising from under the Fair Trading Act;
labelling changes are needed only for the specific bread range affected, therefore reducing labelling costs;
an implementation period of less than twelve months;
an increased level of folic acid fortification for targeted bread range, delivering greater benefit to target population
if fortified at a higher level, there would be a reduced need for the target groups to consume supplements to reach the optimum effective level;
industry would support an education campaign that promotes public awareness of fortified breads;
the ability of industry to make an appropriate health claim, critical for a promotion campaign;
a government funded public campaign to promote the role of folic acid in NTD prevention is essential to ensure consumers support the proposed fortification;
the proposed fortification approach would allow time for the reporting from the UK Scientific Advisory Committee on Nutrition, for gathering of further data on NTDs in NZ, the impact of the recommended approach, data on current folate intake of NZ population, further data on risk of reaching UL in NZ children, more information on B12 of elderly New Zealanders, and for gathering further food consumption data to determine the most suitable food vehicle.
Acknowledge that fortifying all bread flour is the only way to ensure all bread in NZ is fortified.
Disadvantages of alternative proposal include:
compliance issues for artisan bakers (who produce bread from scratch, estimated at less than 5% of the total bread consumed.
may miss the target population who purchase bread from artisan bakers.
Notes that NZAB is willing to work with the agencies concerned on the alternative proposal.
I16
New Zealand Flour Millers Association
Mr Andy Worrill
Supports a modified option 2 Supports the alternative proposal from the NZ Association of Bakers.
Impact on Industry
Technical difficulties
Few mills in New Zealand have the delivery systems that are sufficiently accurate to add folate to flour within the very narrow range of levels specified in the proposal. Some flour will therefore be fortified with folic acid to a level that is ineffectual in achieving the public health objectives of the proposal, and some flour will contain levels of folic acid in excess of the maximum specifications and overdosing will occur.
The measured results for mandated thiamin additions to flour vary considerably (62% monthly variances); if this is applied to folate levels could be considerably in excess of maximum levels.
The costs of acquisition and installation of these delivery systems are prohibitive, and would be passed onto consumers of flour (indicative costs have been provided to FSANZ recently). Smaller mills will not be able to meet this level of capital expenditure.
Compliance risks
Industry will be placed in the position of being unable to meet its legal requirements if folate is mandated for addition to flour at the proposed levels. With the likely variation in folate levels it is likely levels will fall outside the specifications. Meeting the specifications is not possible without new plant. The inability to meet specifications will have a flow on effect to other industries that are also required to disclose product information.
Affected exporters have all confirmed that the noting of folic acid on product labels will create barriers in their export markets. Exporters would also be unable to prevent cross contamination between domestic fortified and export non-fortified flours, resulting in lost markets or rejection of shipped flour.
Consumer choice
The proposal refers to fortifying ‘bread flour’ with the inference that there are a number of other available flours. The concept of ‘bread flour’ is misleading, as generally mills produce one type of flour. Any variations are made post production.
Therefore the suggestion that flour can be produced as either fortified or non fortified is erroneous.
Consumers will in reality have little choice as to whether they purchase fortified or non fortified flour or flour based products.
Food vehicle / Alternative proposal
The Association supports the proposal by the New Zealand Association of Bakers that folate be added to a specified range of breads, yet to be determined.
The bakery division of George Weston Foods in NZ currently add folate to flour as part of the bread making process for some of their products. This is achieved by adding a folate mix. This method will provide for very accurate amounts of folate to be added, with less likelihood that over or under dosing will occur.
Monitoring of levels of folate in the final bread would be achieved easily as there are approximately 20 production sites in New Zealand.
Greater choice will be provided as flour not containing folate will be available for sale.
I17
New Zealand Food and Grocery Council (FGC)
Ms Brenda Cutress
Supports a modified Option 2
Food vehicle
The assumption that folic acid will be added to bread-making flour only is incorrect, and FSANZ has already been advised that ‘all flours’ in New Zealand will be fortified as segregation of bread-making flour is not possible.
Submits that given the identified risks in the risk assessment, should have reviewed the food vehicle for one with less impact on the general public.
Whilst fortifying flour with folic acid is consistent with international experience, there has also been a consumer choice option, which is denied NZ consumers
Ministerial Council Policy Guidelines
The food vehicle, bread-making flour, does not meet the Ministerial Council Policy Guidelines for mandatory fortification as it is does not deliver effective amounts of the added vitamin to the target group to meet the health objective.
The target group do not consume bread in the quantities necessary to achieve the mean increase of 131 ug per day (NZ women) recommended in the proposal. On the consumption estimates used by FSANZ for Australia and New Zealand, almost 20% of women in the target group will not receive the beneficial effects of the proposal. Research of bread consumption by the major baking companies also shows that the bread intake of the target groups is 1-2 slices per day, which will result in the ineffective increase (40-80 ug/day), which is contrary to the specific order policy principles that mandatory fortification deliver effective amounts of the added vitamin.
The effective intake of folic acid for NTD reduction is 400 ug folic acid/day.
This proposal will not achieve this goal in 98% of NZ women and 95% of Australian women in the target group. Folic acid supplementation and consumption of other folic acid fortified foods will still be necessary, yet FSANZ recognises that 50% pregnancies are unplanned, and reliance on supplements is not appropriate, which is a contradiction. More effective strategies need to be adopted.
Consumer choice and labelling
New Zealand consumers will have no ability to consume non-fortified flour under the proposed regulatory option; therefore FSANZ is incorrect in stating that consumers will still be able to purchase non-fortified flours.
Believes that FSANZ acknowledges the recent NZ studies which show that that NZ consumers are strongly opposed to the mandatory fortification of bread with folic acid yet notes it is difficult to assess the likely response of consumers to mandatory fortification because of lack of research on likely consumer responses.
FGC recognises that other countries have taken a mandatory fortification approach in respect of bread, but there has always been a consumer choice option of non-fortified bread available, which will not be the situation in New Zealand.
Trade and export implications
The proposal will have a significant effect on international trade, particularly NZ manufacturers that export to Asia. Insufficient attention was given by FSANZ to the trade implications of the proposal, and this is required under the FSANZ act.
The majority of markets to which flour containing products are exported require unfortified products. Cereal flour and baking mixes, bread doughs and premixes, and cake and pastry contribute $14.2m, $67.3m, and $2.7m to export earnings respectively. Additionally, a proportion of confectionery (contributes $114.7m to export earnings) and a large range of exported crumbed products will be affected by the proposal. The Japanese export market is a particular concern, and as an example a frozen dough exporter has recently had to remove an enzyme in their formulation for the Japanese market, and experienced significant costs of over $1m.
The addition of folic acid to breads that make organic or ‘natural’ claims will be in breach of the Fair Trading Act, and this issue should have been considered in the Proposal.
Technical feasibility
It will be impossible to guarantee the level of folic acid fortification between 230-280 ug/100 g flour. The experience of thiamine in Australia demonstrates the difficulty in controlling dosage levels, and the setting of an upper and lower limit with respect of folic acid is even more difficult. The quantities of folic acid in the final product will be highly inaccurate.
