Proposed Mandatory Fortification of Rice and Edible Oils —A Wasteful and Harmful Proposal Best Avoided


Recently a controversy has erupted around the  ‘planned mandatory fortification of Edible Oil with Vitamin A and Vitamin D and Rice with Vitamin B12, Iron and Folic Acid’, as announced by the Food Safety and Standards Authority of India (FSSAI). Early this year the FSSAI had issued draft regulation for mandatory fortification of edible oils and proposal for mandatory fortification of rice after some time.

ASHA Kisan Swaraj, an alliance with affilation of around 400 groups working on organic and natural farming and food systems,  has responded to this  with a very detailed letter addressed to the authorities which has been endorsed by about 170 persons who are very well-informed on food and health issues. These include Kavitha Kuruganti , Convenor of ASHA ( Alliance for Sustainable and Holistic Agriculture, Usha Solapani ,Co-convenor of ASHA, Prof. Jayati Ghosh, Dr. Debal Deb, Dr. Vandana Prasad, Dr. Mira Shiva and Aruna Rodrigues. In view of the importance of this issue for our food system the important facts and evidence highlighed in this letter need to be known widely. This letter has also provided innumerable references for various assertions.

Establishing the real nature of nutrition problem in India this letter says that undernutrition in the form of protein and calorie inadequacy is a fundamental problem in India, which the WHO confirms is a certain contributor to vitamin and mineral deficiency. Monotonous cereal-based diets, and low consumption of vegetables, eggs, milk, flesh foods, and fish have worsened the nutritional scenario, resulting in multiple vitamin and mineral deficiencies. According to the latest NSSO data, the share of calories from protein sources for Indians is only 6–8% . In such a scenario, adding one or two synthetic vitamins or minerals in the absence of adequate calorie and protein consumption may in fact be toxic and have adverse outcomes in undernourished populations . For instance, iron fortification is known to have caused gut inflammation and pathogenic gut microbiota profile in undernourished children .

This letter points out that fortification with one or two chemicals to address one nutrient deficiency will be limited by another nutrient deficiency.  For e.g. haemoglobin synthesis requires not just iron but good quality proteins and many other micronutrients as well . Apart from iron, Vitamins A, C,E, B2, B6, B12, folate, magnesium, selenium, zinc are needed for hemoglobin synthesis. Only a diet that contains good quality proteins, vitamins and minerals will be able to address multiple nutrient deficiencies.

The ASHA letter draws attention to several studies that challenge the efficacy of fortification. The 2021 study by experts from the ICMR, AIIMS and the Ministry of Health published in the Journal of Nutrition highlights that increasing iron intake alone has no impact and cannot replace dietary diversity, which facilitates iron absorption while providing all other hematopoietic nutrients . A meta-analysis of data from several rice eating countries shows that rice fortified with iron, vitamin A, or folic acid made no difference to anemia and little difference to Vit A deficiency . Even for double fortified salt (DFS), which is widely promoted by the government through PDS and mid-day meals programs, large scale trials of effectiveness don’t exist and there is little evidence of efficacy, while organoleptic changes have been significant.

Another important concern highlighted in this document  is the high level of carbohydrate consumption in India which is linked to diabetes, hypertension, heart disease and makes the focus on cereals as the vehicle of mandatory fortification as ill-advised as it will create a further dependence on cereals for essential vitamins and minerals at the cost of other nutrient dense food groups.

What is more, this letter ponts out that there is no consensus about the prevalence of vitamin and mineral deficiencies in India. For instance, according to one set of scientists, anemia is over diagnosed based on their 2021 study published in the Lancet conducted by Indian scientists . Yet another 2021 study by researchers from the National Institute of Nutrition, St Johns, and the Sitaram Bhartia Institute of Science and Research published in the American Journal of Clinical Nutrition and based on latest CNNS (Comprehensive National Nutrition Survey 2018-19) data show that vitamin A deficiencies in young children are no longer a public health problem. They warn that continuing with supplementation programs, and we include mandatory fortification, can lead to hypervitaminosis. Such studies are contradictory to FSSAIs portrayal of national scale deficiencies. The ASHA letter asks–how can any large scale and mandatory fortification program be put in place when such confusion exists about the extent of nutrient deficiencies?

Indeed, the picture of national scale vitamin and mineral deficiency differs across classes, and regions requiring diverse and localized approaches. On he other hand, this ASHA document says, FSSAI’s portrayal shows that the government is comfortable with contradictory evidence used opportunistically to defend its inaction to address the issue of malnutrition holistically and to facilitate agribusiness led reductionist solutions.

Coming to livelihoods related issues, the ASHA document points towards  existing evidence which shows that mandatory fortification of foods will have adverse economic impacts on consumers as well as informal players like small rice millers, oil ghanis/cold press oil mills, small farmers, and local enterprises. According to the FSSAI, international corporations will have the key role in supplying micronutrients, while Indian manufacturers will develop pre-mixes for essential food commodities, but there is no mechanism in place for price control of such micronutrients. Just five corporations have derived most of the benefits of global fortification trends and these companies have historically engaged in cartelizing behaviour leading to price hikes. The EU has even fined such companies for their cartelizing behaviour.

The ASHA document points out that the process of rice fortification itself is expensive and mandatory fortification being expensive will lead to many  small rice millers shutting down.  An indicative cost of producing rice through fortification for a medium sized mill is Rs 3.2 crore (as mentioned in Pilot Scheme Fortification of Rice and its Distribution under Public Distribution System). The rice millers associations in Punjab and Haryana had been protesting against these new norms of fortification of rice since March 2021, and have forced the FCI to relax norms .

As emphasized in this document, globally and in India, studies have shown that fortification programs lead to increased market share of formal players, and reduce market share of the informal sector . Even if small players are able to undertake such fortification activities, the costs for them are prohibitive. Evidence shows that large-scale processing firms tend to coordinate with larger producers through contracts to secure scale and homogenous quality of raw material supply . Even when included, smallholders may not always benefit from contracts . This document raises an imortant question– Given the centrality of agrarian livelihoods to India, has the FSSAI conducted any economic and social impact studies on long term impacts of centralized and corporate led food fortification on livelihoods and local economy?

The FSSAI has said that fortification is a ‘cost effective’ option for easy nutrition to the masses. However, the ASHA document ponts out that long-term costs of fortification will be profound and irreversible. Mandatory fortification will lead to irreversible infrastructural and market shifts, including consolidation of corporate power. Current fortification schemes will create a market of over 3000 crores for just 5 big companies.

A worrying long-term consequence of fortification, this document points out , is that it creates reliance on packaged foods and removes the focus from local foods, their production systems and eating practices.The FSSAI appears to be wilfully ignoring such conflict of interest by industry before promoting their products in the form of mandatory policy without any independent studies.  There is a need for more independent studies not only on fortification but also comparing it with better and cheaper solutions. For example, this document asserts, it would be more effective to tap into the appropriate varieties of staple foods in a particular region, which are naturally rich in vitamin and minerals. Among plant-based foods, there exist at least 68 indigenous varieties of rice with very high (20 – 300 ppm) iron content .Several millets and vegetables are a rich source of iron, zinc and B vitamins. A wide range of vegetables (e.g. tender leaves of taro yam, amaranth, mustard, radish, Ipomea aquatica) and fruits such as pumpkin, papaya, mango etc. are known to contain a copious amount of beta carotene. There are also a range of uncultivated food plants with high amounts of beta carotene and B vitamins and most of these are available at no cost to the rural poor . Several B vitamins have also been found in more than 300 folk rice varieties. These same rice varieties and vegetables also contain calcium, zinc and phosphorus.

Locally made fortificants or food-to-food fortificants, the  ASHA document points out, are another effective intervention to address vitamin and mineral deficiency. These include syrups, biscuits, porridges, powders and various products made from locally available ingredients . These can improve nutritional status while also supporting local livelihoods and small local businesses.

The document says that community level nutrition approaches, like kitchen gardens, fish ponds, backyard livestock are proven methods in improving household nutrition security. Local households, women’s groups, farmers collectives, small businesses can easily be supported via such approaches to play a role in feeding their communities especially in times of crises like the recent pandemic. Several kitchen garden efforts have successfully reduced vitamin and mineral deficiencies, improved dietary diversity and protein consumption, and led to deep community level education around nutrition.

Reducing processing from polishing or refining is another important recommendation that FSSAI must make, this letter asserts. For rice, the obvious solution is unpolished/less polished rice which has more nutrients. For edible oil, promoting unrefined cold pressed or filtered oils which are known to be more nutritious must be promoted. It is a tragedy, the ASHA government says, that first vitamins and minerals in oils and rice are removed via polishing or refining and added later on at a huge cost in the name of fortification.

The real problem  relates, this letter says, to  the poor access of most people to nutrient dense foods in adequate quantities. Addressing individual deficiencies with mandatory fortification is not a solution but only a way of routing public funds to the corporate sector. The document says emphatically–We would like to urge that reductionist, pro corporate, irreversible, and unnecessary steps like mandatory fortification are not taken at the expense of our food sovereignty and dietary diversity.

Bharat Dogra is a journalist who has reported extensively on food and farming issues.

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