Proposed Amendment to the New Zealand Folic Acid Standard

The Soil & Health Association of New Zealand Inc remains supportive of the position of the existing Standard to exempt organic bread from mandatory fortification with folic acid.
Soil & Health remains opposed to the mandatory fortification of all bread, but is pleased that the integrity of organics was supported by then Food Safety Minister Annette King, the Commerce Commission and FSANZ. The exemption of organic bread allows a measure of choice for all consumers and generally has the advantage of having higher base levels of natural folate than many other types of bread, due to the ingredients being less processed.
Soil & Health received significant communication of support from members and also several organic bakers to the news of the organic exemption. Soil & Health interprets the current Standard as protecting the integrity of organics, a position it expressed in consultation and submissions to FSANZ and the Food Safety Minister.
Soil & Health agrees with the substance of the New Zealand Commerce Commission (NZCC) and Australian Competition and Consumer Commission (ACCC) findings in relation to consumer expectations of foods labelled ‘organic’ or ‘certified organic’, as expressed in the earlier Issues Paper.
Soil & Health has some degree of concern that foods labelled ‘natural’ were not exempt, however unless those foods are reasonably certain to be pesticide and additive residue free, as expected with organic foods, the ‘natural’ claim may be spurious.
Foods labelled ‘natural’, are without the benefit of standards and certification processes as in the organic sector, however should a food supplier be able to provide evidence of the ‘naturalness’ of its product, for example wild harvested and organic ingredients with no synthetic additives, Soil & Health would expect that it should also be exempt.
Soil & Health supports increased education of the community and in particular women of childbearing age, of the function of folate in NTD prevention, and Soil & Health accepted it has a role with its membership of communicating that function, the dietary sources and options available.
Of the suggested options
* 5.1 Status Quo
* 5.2 Amendment to Commencement date (preferred option)
* 5.3 Revocation of the New Zealand Folic Acid Standard

Soil & Health prefers option 3 (5.3), Revocation of the NZ Folic Acid Standard.
Revocation of the Standard in conjunction with a strong public health educative program that not only targets women of child bearing age, but educates the public in general to the benefits of folate and a healthy full diet.
Noting that there are significant increases in obesity and other symptoms of poor dietary choice, there is an opportunity to address folate intake as part of a more comprehensive nutritional campaign that will have benefits far in excess of the most optimistic outcomes of mass medication, and without the possible risks associated with synthetic folic acid or other mandatory supplements.

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