Drafting Submitter FSANZ response If the NPSC is applied to fortification of MPI Noted. See Review Report, breakfast cereal with vitamin D, particularly section 7 and consideration should be given to a draft approved draft variation (as variation that requires the same relevant amended) at Attachment A. additional labelling requirements to be met as outlined in Division 7 of Standard 1.2.7. This will assist enforcement agencies to determine if a given breakfast cereal meets the NPSC as all relevant details will be provided on the label. Future / precedent setting Submitter FSANZ response The application of the NPSC more widely NZFGC Noted, This review related only to across the food supply to fortification the voluntary fortification of decisions already made, and to breakfast cereal with vitamin D. proposals in the future raises concerns. However, FSANZ understands There may well be flow on effects as a that the clarification statement, result affecting a much broader range of clarifies the Policy Guideline applications. Ingredient suppliers will Fortification of Food with vitamins the region as unworthy of and minerals more broadly, and investment because: will therefore be considered as part of the assessment in future the costs associated with making fortification applications or applications and proposals. outcomes can be and are shown to be perverse. This may have a significant and negative Noted. impact on food choices, innovation and development and ultimately on the economics of manufacturing for Australia and New Zealand. It is not clear if proposal A1090 extends to Kellogg Noted. See response above. foods already fortified with vitamins and minerals that are not meeting the NPSC. Concern that fortification of breakfast Tasmania Some of the mentioned foods in cereals may be extended similar foods this submission are already (precedent setting) permitted fortification e.g. breakfast drinks already permitted to contain 5 µg vitamin D per serve. FSANZ assesses each fortification on its merit. See response above. Principles for fortification Submitter FSANZ response Fortification should only be permitted OPC Noted. See Review Report, where the demonstrated public health particularly sections 4, 5 and 6. benefit outweighs the risk of increased FSANZ has had regard to the consumption of foods not in line with Policy Guideline which aligns ADG. with Codex principles: General Principles for the Addition of Essential Nutrients to Foods (CAC/GL 9-1987)
Drafting Submitter FSANZ response If the NPSC is applied to fortification of breakfast cereal with vitamin D, consideration should be given to a draft variation that requires the same relevant additional labelling requirements to be met as outlined in Division 7 of Standard 1.2.7. This will assist enforcement agencies to determine if a given breakfast cereal meets the NPSC as all relevant details will be provided on the label. MPI Noted. See Review Report, particularly section 7 and approved draft variation (as amended) at Attachment A. Future / precedent setting Submitter FSANZ response The application of the NPSC more widely across the food supply to fortification decisions already made, and to proposals in the future raises concerns. There may well be flow on effects as a result affecting a much broader range of applications. Ingredient suppliers will the region as unworthy of investment because: the costs associated with making applications and outcomes can be and are shown to be perverse. This may have a significant and negative impact on food choices, innovation and development and ultimately on the economics of manufacturing for Australia and New Zealand. NZFGC Noted, This review related only to the voluntary fortification of breakfast cereal with vitamin D. However, FSANZ understands that the clarification statement, clarifies the Policy Guideline Fortification of Food with vitamins and minerals more broadly, and will therefore be considered as part of the assessment in future fortification applications or proposals. Noted. It is not clear if proposal A1090 extends to foods already fortified with vitamins and minerals that are not meeting the NPSC. Kellogg Noted. See response above. Concern that fortification of breakfast cereals may be extended similar foods (precedent setting) Tasmania Some of the mentioned foods in this submission are already permitted fortification e.g. breakfast drinks already permitted to contain 5 µg vitamin D per serve. FSANZ assesses each fortification on its merit. See response above. Principles for fortification Submitter FSANZ response Fortification should only be permitted where the demonstrated public health benefit outweighs the risk of increased consumption of foods not in line with ADG. OPC Noted. See Review Report, particularly sections 4, 5 and 6. FSANZ has had regard to the Policy Guideline which aligns with Codex principles: General Principles for the Addition of Essential Nutrients to Foods (CAC/GL 9-1987)
A1090%20Vit%20D%20in%20breakfast%20cereal%20SD3%20Summary%20of%20subs.docx