Questions and Answers - Food Fortification Proposed Policy

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1. Why is Health Canada reviewing its policy on food fortification?
   
   The review responded to concerns that the current food fortification policy and practices are too restrictive and that they limit the development of new products, as well as Canadians' access to fortified foods available in other countries. Health Canada's response to these requests was to re-visit the premises that had guided food fortification in the past, apply new science, and arrive at a proposed new policy.
   
   The proposed policy retains current fortification practices such as restoring vitamins and minerals lost through processing and correcting and preventing nutritional problems of public health significance.
2. What are the benefits to allowing increased fortification?
   
   There are a number of benefits to Canadians in the new policy. We anticipate that, when manufacturers fortify their products (within the safe limits set by Health Canada), the nutrients available in our food supply would increase. Canadians would enjoy the freedom to make choices from a wider range and variety of fortified foods while knowing that they have been protected from the health hazards of consuming too much of a given nutrient.
   
   In addition, the proposed policy complements the government's Smart Regulations Strategy as it would allow for the innovation and development of new fortified products in Canada and reduce regulatory differences between Canada and the United States.
3. Are there any risks to allowing increased fortification?
   
   Protecting the health of Canadians is Health Canada's first priority when making decisions about food fortification as it is indeed possible to get too much of some nutrients. This is why the proposed policy would set specific limits on what nutrients can be added to food, how much of an individual vitamin or mineral can be added, and which foods can not be fortified at the discretion of manufacturers.
   
   
4. Is Health Canada advocating these new fortification measures because there's something wrong with our diet?
   
   No. With few exceptions, the Canadian food supply is very good, with year round availability of a great variety of fresh and wholesome foods.
   
   As well as being abundant, our food supply is nutritious, in part, because Health Canada has in the past intervened with mandatory fortification programs to protect the health of Canadians in situations of dietary inadequacies. One example of how mandatory fortification has improved the nutritional quality of Canada's food supply is the requirement for milk to be fortified with Vitamin D, a practice which virtually eliminated the childhood deficiency-disease rickets in the 1970's. More recently "enriching" flour with folic acid has helped reduce the incidence of birth defects. For over fifty years, mandatory fortification practices have proven to be an effective public health intervention.
   
   
5. Why is Canada's approach to discretionary fortification different than other countries?
   
   Internationally, the Codex Alimentarius Commission of the Joint Food and Agriculture Organization and the World Health Organization has set out general principles for the addition of vitamins and minerals to foods. However, each country determines its own policy or regulations. As a result, approaches to fortification vary widely throughout the world.
   
   Health Canada's science-based approach has resulted in what could be considered a typical Canadian approach. For example, our proposed discretionary fortification limits are more conservative than the United States, but more liberal than some European countries. It should also be noted that the US has not updated its approach in more than 25 years.
   
   
6. How are foods fortified? Are nutrients added or is the food modified in some other way to increase its vitamin/mineral content?
   
   Foods are generally fortified by the addition of acceptable purified forms of vitamin and mineral nutrients directly to the food. The acceptable vitamin and mineral nutrient forms may be man-made or derived from naturally occurring products. Adding certain nutrients may affect the taste or colour of the food, but do not otherwise change the components of the food in any other respect.
   
   
7. What is regulated discretionary fortification?
   
   Some fortification, such as Vitamin D in milk and folic acid in flour, is required by the government on the basis of a public health need. This type of required additions of vitamins and minerals is called mandatory fortification. Regulated discretionary fortification, on the other hand, is food fortification (within defined limits set by Health Canada) done at the "discretion" or "choice" of the manufacturer to meet a market demand or to potentially open new markets for their products.
   
   
8. Would food manufacturers be allowed to decide what nutrients they can add to a food under regulated discretionary fortification?
   
   
   Yes, within the regulations to be set out - which limits what foods can be fortified and the type and amounts of vitamins and minerals that can be added.
   
   
9. Does this mean that all foods would soon be fortified?
   
   No, not at all. Certain standardized and staple foods in the food supply would be excluded from regulated discretionary fortification to guard against excessive nutrient intakes. Examples include flour, bread, pasta, rice, milk, butter, sugar, and salt. Fresh fruits and vegetables, eggs, nuts, fresh meat, fish, and poultry are also excluded from discretionary fortification because these foods already are good sources of one or more nutrients naturally occurring. In addition, consumers indicated that they wanted to maintain a choice of unfortified foods, including those that are already healthy. Also, we know from our American colleagues, where there is a mature market and more relaxed control of food fortification, that not all foods are fortified even when manufacturers are permitted to do so.
   
   
10. But won't this mean that junk food can be fortified and be marketed as nutritious food?
    
    Any food subject to discretionary fortification would have to display the new Nutrition Facts table that shows not only nutrients such as Vitamins A and C, calcium, and iron, but also Calories, the amount of fat, saturated and trans fats, cholesterol, sodium, carbohydrate, fiber, sugars, and protein, in a specified amount of food. This will help consumers to make healthy food choices. (For more information on the nutrition labelling regulations visit www.healthcanada.ca/nutritionlabelling.) From focus testing we know that consumers use labels and are already very aware of saturated and trans fats, sugar and sodium content and labelling of foods and that they make choices accordingly. The proposed policy would allow such foods to advertise themselves as "good" or "excellent" sources of specific nutrients provided they meet standards specified by Health Canada, but, as noted, the nutrition facts panel must also be present.
    
    
11. Won't fortifying high-fat or high-sugar foods (so called junk foods) lead to an increase in Canada's obesity problem?
    
    Health Canada is certainly concerned about the rising rate of obesity in our country, one that led us to explore how consumers would react to possible fortification of so called "junk" foods. Health Canada conducted focus group testing across the country to test, among other things, whether Canadians would be more likely to choose fortified "junk" food over healthy food should manufacturers start fortifying these products.
    
    In these focus groups, we were told that Canadians are unlikely to choose foods of limited nutritional value over healthy food simply on the basis of fortification. There is also no evidence that people living in Canada would increase their consumption of "junk" foods should they be fortified; for example, those who already consume ice cream or carbonated beverages indicated that they might choose the fortified counterpart if there was no difference in any other aspect of the food including taste and price, but they did not indicate they would consume more.
    
    Health Canada will actively monitor and evaluate the effects of the new regulations. Based on new information that may emerge, the nutrients and/or levels permitted to be added to foods, as well as the foods that are used as vehicles for fortification, could be revised.
    
    
12. What does Health Canada mean when they say a product can be called a "good" or "excellent" source of a specific nutrient?
    
    These claims can be used for any food that contains sufficient levels of a vitamin(s) or mineral(s) to meet the conditions for the claim. For example, if the total amount of the nutrient in the food is 10% or more of the Daily Value (the amount would be labelled on the Nutrition Facts panel), that food would qualify for a "good source" claim. If the total amount of the nutrient in the food is 20% of the Daily Value then the food would qualify for an "excellent source" claim.
    
    
13. How would Health Canada ensure that products have the amount of nutrients they claim?
    
    The proposed policy requires manufacturers to establish procedures for verifying the content of the vitamins and minerals in their products. To accomplish this, the proposal calls for manufacturers to conduct tests to determine:
    
    
    • the uniformity of distribution of the vitamin or mineral in the food;
    • the stability of the vitamin or mineral in the food;
    • the minimum amount of overage (that is, extra) required to maintain the level of the vitamin or mineral in the food throughout its shelf-life ;
    • for foods with a durable life of more than 90 days, the date after which the manufacturer does not recommend that the food be consumed because the declared levels of vitamins and minerals may no longer be present. This date must be shown on the label.
      
      Manufacturers and importers would also be required to keep records of the tests conducted for inspection purposes.
      
      
14. This is being called a "proposed policy." What are the next steps before this proposed policy becomes "official?"
    
    Health Canada will be drafting proposed regulatory amendments to implement the policy. These will be published in Canada Gazette Part I for comments by stakeholders. All comments have been and will continue to be considered and final regulatory amendments will be prepared for publication in Canada Gazette Part II based on an evaluation of these comments.
    

For more information on food fortification, visit www.healthcanada.gc.ca/fortification.