Mandatory fortification of iodine in bread

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Submission to: Food Standards Authority New Zealand
Submission Author: Steffan Browning, Soil & Health Association
Tuesday, September 19, 2006

Below is the Soil & Health NZ submission to FSANZ’ Proposal for Mandatory Fortification of Iodine in bread.

Bar influence by Food Safety Minister Annette King at the October 25 Ministerial Council meeting, folic acid which has already been recommended by FSANZ, will be likely joined by iodine to be included in NZ bread including organic bread.

Annette King can either press her Australian equivalents, state and federal, to call for a review of the FSANZ decision to allow, for example, an exemption for organics from any mandatory fortification, or the Minister can take New Zealand down a different path than the Australians as happened with Country of Origin Labelling. The Minister has the power. Or of course Australian ministers can call for an organic exemption.

Mandatory fortification of any NZ foods has not occured before. All fortification has been voluntary, including the high uptake of iodised salt in the past. This is a serious intrusion into free choice of all consumers and the integrity of NZ organics.

We have been given support by MPs from two parties so far and given opportunity it would be useful to put our concerns to any MPs that you come in contact with, particularly those close to the Labour Government. This is not new legislation it is over to the Minister.

Remember FREE CHOICE and an ORGANIC EXEMPTION.

Thanks
Steffan
Spokes
person

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Submission to Food Standards Australia New Zealand

Re: PROPOSAL FOR MANDATORY FORTIFICATION WITH IODINE (Proposal P230)

The Soil & Health Association of New Zealand Inc is 65 years old, and is the largest membership organisation supporting organic food and farming in New Zealand, and as such advocates for a healthy natural diet derived from food produced organically and free from additives.

In the event of mandatory fortification of either or both, iodine and folic acid, Soil & Health recommends an exemption for organic foods.

Soil & Health is conscious of the need for good nutritional education and supports strategies that explain the necessity and sources of iodine in diet, and those factors which suppress adequate iodine uptake.

Soil & Health is concerned that other components such as some soy products and fluoride in the contemporary diet may be factors in the rise in iodine deficiency. Organic consumers prefer a solution to the cause, rather than focus on treatment of symptoms.

In the event of need for supplementation, natural products as ingredients are preferred.

Seaweeds are used by some organic consumers with an awareness of the added need for minerals such as iodine, and certified organic kelp – seaweed products exist with that market in mind.

Acknowledging the high level of nutritional and health awareness of organic consumers, in the event of an exemption for organic foods from fortification, monitoring will show any need for increased education or recommendations to that consumer sector.

Fortification with any synthetic additive is contrary to the ideals of the consumer base of Soil & Health’s membership, and mandatory fortification will reduce choice for those wanting to avoid additives.

That said, many pregnant and breastfeeding women in Australia and New Zealand, in the absence of adequate iodine intake or subject to goitrogenic factors, may require daily iodine supplements.

FSANZ states in the draft assessment report that fortification will not be enough to address iodine status shortfalls.

Soil & Health agrees that an education program through the health system, including information on iodine sources and inhibitors is required, with optional supplementation a possibility.

This does not necessitate mass medication and in that event, broader consumer choice than unleavened bread and a few cereals is appropriate. Considering typical diets, the unfortified choices suggested in the Proposal assessment report are not really choice at all.

Soil & Health is aware of small domestic market focused bakeries that would have difficulty complying with the proposed standard for mandatory fortification with iodine. Those bakeries, and also access to markets requiring no added iodine, need to be allowed for in the interests of fair trade. Regulation as recommended so far disadvantages small commercial operations. An exemption for organic foods would reduce the level of commercial disadvantage.

Organic production and processing is based on minimum alteration or addition to food composition. Organic processing standards restrict additives in bread. BioGro for example would have to change its standard to something less than consumer expectations if mandatory fortification was introduced.

The current voluntary fortification regime allows consumer choice and fair trade as long as clear labelling is present.

FSANZ’ Proposal states, ‘Food labeling or promotional claims must be factually correct and not misleading or deceptive under the fair trading legislation of Australia and New Zealand. FSANZ intends to discuss the use of descriptors such as ‘natural food’, and ‘organic foods’ with the

Australian Competition and Consumer Commission and the New Zealand Commerce Commission, to clarify the status of foods using iodised salt with regards to fair trading”

An appropriate descriptor or definition of ‘organic’ produce or goods is likely and appropriately that which has been produced according to either a ‘National’ organic standard, or is organically certified. The 12 month transition period for implementation allows more than sufficient time for that mechanism to be established.

At least three organic certification organisations in New Zealand:
1. Organic Farm NZ Incorporated
2. BioGro Producers and Consumers Council owners of BioGro NZ Certification and BioGro Domestic Organic Certification
3. The Biodynamic Farming and Gardening Association, Demeter certifier in New Zealand, do not agree with mandatory fortification of organic food and in principle agree with an exemption for organic food.

The Soil & Health motto is Healthy Soil , Healthy Food , Healthy People.

Below a paragraph that expresses the principle as presented by one of our prolific members.

“Under genuine organic management the inherent expectation and principle is that the produce grown takes up and produces enough iodine and folic acid to satisfy a person’s need when consuming a balanced organic diet.

While this is not yet necessarily always the case it is the aim of the organic production system to produce ‘whole foods’ in the true sense of the word. We are better off exploring what is required to get acceptable levels in our food crops again and pay the true and fair price for producing quality food.

Giving in to external pressure to fortify foods takes away the only natural option to explore what is required to grow ‘quality’ food and gives producers and wholesalers a cheap and easy way out. It encourages a commodity/quantitative approach (factory farming vs organic farming) and prevents a focus on quality food production. A regulation that encourages fortification encourages poor food production systems!

An exemption would allow the organic producers to continue exploring genetic material and growing methods that deliver ‘genuine’ organic whole foods and will also give consumers a choice”.

Summary

* The Soil and Health Association of New Zealand does not support Mandatory Iodine Fortification.
* Soil & Health supports public education of the need for iodine, sources of iodine and factors that inhibit the uptake of iodine.
* Soil & Health supports informed and fair consumer choice.
* In the event of FSANZ choosing to pursue a Mandatory Fortification regime, Soil & Health requests that an exemption be made for Certified Organic producers and processors.
* Soil & Health and other organic organisations in New Zealand and Australia wish to explore with FSANZ, options for an organic foods exemption from mandatory fortification.