Regulations on supplementing micronutrients cause waste and ineffectiveness for food businesses

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Ms. Ly Kim Chi, President of Ho Chi Minh City Food Association.

In response to the shortcomings, the Ho Chi Minh City Food Association and a number of industries have repeatedly proposed in a hope to timely lift difficulties for businesses in the food processing industry.

How do the mandatory regulations in Decree 09/2016/ND-CP on fortifying food with micronutrients affect food businesses, ma'am?

On January 29, 2016, the Government issued Decree No. 09/2016/ND-CP regulating the fortification of micronutrients in food. In particular, the provisions in Points a and b, Clause 1, Article 6 of Decree 09 are: "Salt used in food processing must be fortified with iodine" and "Wheat flour used in food processing must be fortified with iodine, iron and zinc”. This regulation has imposed difficulties on businesses processing food for export and domestic consumption for nearly 8 years. Not only that, this regulation is still ineffective in improving micronutrients for people, which can lead to the risk of harming the health of groups with enough and excess micronutrients.

On May 15, 2018, the Government issued Resolution No. 19-2018/NQ-CP and directed the Ministry of Health to "Research, amend and supplement Decree 09 in the direction of: abolishing the regulation on "salt for use in food processing must be fortified with iodine" and abolish the regulation "wheat flour used in food processing must be fortified with iron and zinc". Instead, food-processing businesses should only be encouraged to use it. On June 26, 2018, the Ministry of Health issued Plan No. 618 amending Decree 09 but it has not been implemented to date.

Currently, the Draft Decree amending and supplementing a number of articles of Decree 09 chaired by the Ministry of Health has just been developed and is being sent for comments from ministries, branches, international organizations and a few treaties. Food industry association. However, this draft still does not mention amending Article 6, Clause 1, Decree 09 regulating the use of iodized salt and wheat flour in food processing, as stated in Resolution 19.

As you mentioned, the problem has not been completely resolved, so what are the shortcomings that are challenging businesses in the food industry, ma'am?

We have provided specific evidence that the use of iodized salt in food production is not consistent with science and risk management, is not consistent with practice as well as international experience, causing serious great difficulties for production and business. In addition, this regulation only pays attention to the benefits of micronutrient supplementation for deficient groups of people without taking into account the health risks of groups of people with enough or excess micronutrients.

According to the draft, the Ministry of Health has been taking away consumers' right to choose. This is especially harmful to the health of people with excess iodine, hyperthyroidism, etc. As for competitiveness in the domestic and export markets, this regulation increases production costs, darkening food coloring, causing a decline in the competitiveness of businesses.

In the production of traditional fish sauce, the regulation of adding iodine only causes additional costs and changes the natural color and taste of fish sauce because sea fish is already rich in iodine. Not to mention, the added iodine is almost completely lost during processing.

Notably, some main export markets do not accept foods with added iodine, typically, export businesses to Japan must have a certificate of not using iodized salt to export and they must expense more to adjust the production process accordingly. The same negative effect also occurs when implementing the regulation "wheat flour used in food processing must be fortified with iron and zinc".

So, what are your suggestions for the draft Decree amending and supplementing a number of articles of Decree 09?

According to comments from representatives of businesses and food business associations, we recommend that food processing businesses should not be required to use iodized salt or add iron and zinc to wheat flour in food Processing. Instead, the Government should only encourage the addition of iodine to salt and iron and zinc to flour used in industrial food processing. Enterprises will also find suitable production directions to incorporate friendly micronutrients into products so that the final must ensures the required nutritional index.

The business community and food industry associations also hope that the Decree amending and supplementing a number of articles of Decree 09 will be consistent with the scientific basis and risk management, consistent with reality in the food industry of both domestic and international practices.

Thank you very much!