A look at the mandatory so-called 'fortification' of flour in the UK
The Real Bread Campaign's additive-free definition of Real Bread has the (unwritten) caveat of: except for the flour 'fortificants' required by UK law.
The Real Bread Campaign believes that everyone has the right to choose to eat Real Bread, that is to say: made without the use of any so-called processing aids or other artificial additives.
The current, long-standing mandatory addition of four ‘token’ nutrients to most UK-milled flour all but denies people in Britian this right, leaving us with few options: Real Bread made with wholemeal or imported flour, or not eating bread at all.
The Real Bread Campaign believes that the so called ‘fortification’ of UK-milled flour is a ‘sticking plaster’ approach, which fails to address the underlying reasons why some people are living with, or are at the risk of, nutritionally deficient diets. Various questions about the need for, and efficacy of (and even potential risks of) the addition of some of these ‘fortificants’, are frequently raised when flour ‘fortification’ is discussed – in documents issued by the 2013 Defra consultation, for example.
Rather than mandatory so-called ‘fortification’ of flour, the Real Bread Campaign calls for a range of measures to be implemented instead, including:
The extraction rate is the percentage by weight that is ‘extracted’ from the whole grain to make flour. In theory, whole wheat flour contains 100% of the cleaned whole grain; contemporary brown flour is around 80-85% extraction and white flour is about 70-72% extraction.
In traditional milling, as the whole grain is crushed together and then sifted to get lighter flours, even white flour will contain particles of the more nutritious germ and fibrous outer layers. In the modern milling process, however, the different parts of the grain are separated very efficiently, so 70% extraction white flour is almost pure endosperm and will contain much lower amounts of the nutrients that are concentrated in the germ and outer layers of the grain than stone ground flour of an equivalent extraction rate.
Additionally, there is evidence that the high temperatures generated during modern roller milling destroy higher levels of many nutrients than are lost during the cooler stone milling process.
At one time, the addition of chalk to bread was officially recognised as adulteration and banned by law: today, in the name of 'fortification', it is mandatory in almost all loaves in the UK.
Bread and flour regulations
According to The Bread and Flour Regulations 1998:
...must be added to all wheat flour (including stoneground, organically produced and imported) made available in Britain, with the following exceptions:
This is despite a 1981 governmental report (Nutritional Aspects of Bread and Flour) stating that the original and subsequent reasons given for the addition of calcium, iron, thiamin and nicotinic acid to flour were no longer valid, and a 2013 review casting doubt over at least two of the additions.
Therefore, whilst UK millers are subject to these British rules, flour produced and imported from elsewhere is not, as long as it has come from or via a European state in which unfortified flour is legal.
Since the UK implementation of the EU Food Information for Consumers regulation came into force in December 2014, these added substances are now declared on the ingredients lists of flour and loaves.
5 August 2013
An email from the Food Policy Unit of Defra (Department for Environment, Food and Rural Affairs) stated:
'The Government has now completed its review of the Bread and Flour Regulations 1998 in England and in particular the need to continue to fortify flour with calcium, iron, niacin and thiamin. consultation. Defra and DH Ministers have concluded that the existing rules on bread and flour should remain unchanged in England. This decision takes into account an assessment of the health impacts, the impact on industry and on other parts of the UK, and the interests of consumers.
A summary of the Real Bread Campaign's response to the Defra flour fortification consulation.
Everyone has the right to choose to eat Real Bread, that is to say: made without the use of any so-called processing aids or other artificial additives. The current, long-standing mandatory addition of four ‘token’ nutrients to most flour in Britain all but denies us this right. It leaves us with two options: wholemeal Real Bread or no bread at all.
The Real Bread Campaign believes that the so called ‘fortification’ of flour is a ‘sticking plaster’ approach, which fails to address the underlying reasons why some people are living with, or are at the risk of, nutritionally deficient diets. As outlined in the consultation documents, there are various questions about the need for and efficacy of some of these ‘fortificants’. It is regrettable that the review process has not considered alternatives to the addition of the four nutrients to flour as a means to help people to improve their nutritional status.
We call for a fourth and better option to be implemented, which would replace mandatory ‘fortification’ with a range of alternative measures, alluded to in the consultation document, that would reduce the risk of deficiency in any of the four nutrients following their removal from flour.
Download the Campaign's full response here.
Defra has launched a consultation to review the need for, and efficacy, of the current mandatory addition of four nutrients to most flour in the UK. Read more on the Defra website.
In June 2012, SACN published a postion paper titled Nutritional Implications Of Repealing The UK Bread And Flour Regulations.
The Real Bread Campaign is now reviewing this paper as part of the process of drafting its own position statement to submit to the public consultation that Defra has anounced it will hold.
We would be happy to receive from any Campaign member evidence that could be of use to us in determining our position, or an informed comment on this issue - i.e. the possibility of a change to the current mandatory fortification of bread making flour.
You can read a discussion of this issue on Campaign supporter Gerry Danby's Artisan Food Law website.
The last time the government undertook a full review of the need for the addition of 'fortificants' to most UK milled flour was back in 1981. In its report 'Nutritional Aspects of Bread and Flour', the Committee on Medical Aspects of Food Policy (COMA) 'recommended that the addition of calcium carbonate and the restitution of iron, thiamin and nicotinic acid to flour should no longer be mandatory, on the basis that dietary survey evidence available at the time suggested that intakes of these nutrients were adequate, and, in the case of iron, the fortificant was poorly absorbed.' This advice was ignored.
Now, some thirty years later, the Department for Environment Food and Rural Affairs (Defra) is at last reviewing the need for the regulations 'as part of the Red Tape Challenge initiative to reduce regulation in all sectors.' Defra 'will be going out to public consultation on their removal later this year.'
In anticipation of this, in February the government's Scientific Advisory Committee on Nutrition (SACN) met to discuss its recomendations. Here is the draft version of a document titled Nutritional implications of repealing the UK Bread and Flour Regulations it published for discussion at the meeting, and here are the minutes of the meeting.
For more on this issue, see the correspondence below.
The following is an email sent in 2009 by the Real Bread Campaign to the Standards Authenticity and Food Law Policy Branch of the Labelling Standards and Allergy Division of the Food Standards Agency and the reply that we recived from that branch.
email from the Real Bread Campaign to the Food Standards Agency, 11 December 2009
I have been trying to find out when the last time the issue of flour fortification was reviewed in-depth, involving a discussion as to whether flour still should be fortified at all and what the alternatives are, which included considerations such as:
email from the Food Standards Agency to the Real Bread Campaign, 28th January 2010
As you are aware, under The Bread and Flour Regulations 1998, industry is required to add iron, calcium, thiamin and niacin to wheat flour (except wholemeal flour). These requirements date back over fifty years and are intended to restore the levels of these micronutrients to the amounts found naturally in wheat before the milling process, except in the case of calcium which is added for enrichment purposes.
The Food Standards Agency (FSA) has undertaken work on some aspects of these regulations, but no formal review is planned at this stage.
Please find below information in response to your specific questions:
Question 1 – As the national diet has changed significantly since fortification was introduced, do we still need to fortify flour at all?
While the FSA has not considered the extent to which the national diet has changed since fortification of flour was introduced, it has considered the effect of removing fortificants from flour on population intakes of these micronutrients.
In 2007 the FSA analysed data from its National Diet and Nutrition Survey of Adults1 and Young People2 to provide current average intakes of iron, calcium, thiamin and niacin by age and sex, modelled to estimate the effect of discontinuing the fortification of wheat flour with these micronutrients. These estimated intakes were compared with current recommended population intakes3.
The results indicated that fortified flour makes an important contribution to the intakes of at least two of the micronutrients for the population, namely iron and calcium. Removing these from flour would exacerbate low intakes of these micronutrients for certain population groups (e.g. older children and young women) where current intakes are already of particular concern.
However, the situation for iron is complex. Elemental iron powders which are used to fortify wheat flour are not well absorbed and may not have any effect on improving iron status. The Scientific Advisory Committee on Nutrition (SACN) is currently reviewing evidence on iron and health, including iron fortification. It is anticipated that SACN will publish its final report on Iron and Health in early summer, and the Agency will consider the report’s recommendations thereafter.
In relation to thiamin and niacin, discontinuing the fortification of wheat flour with these micronutrients appears unlikely to have an adverse impact as intakes of these nutrients are adequate across the population. However, it is important to note that this was a simple modelling exercise. Before such action could be taken, a detailed risk assessment would need to be undertaken to explore all potential implications for the population of removing these micronutrients from flour.
Question 2 – What alternatives could be employed (e.g. research into wheat breeding and growing methods that considered micronutrients, not just protein and yields; and standardising extraction rates for white and brown flours that would have to include minimum %s of all parts of the grain, including the germ) to maximise intrinsic micronutrient levels without fortificants?
The Agency has limited funds for carrying out research and has to prioritise its resources very careful. It has not carried out any investigations into alternatives methods to supplementation of flour at this time. However we are aware that Campden BRI has an extensive work programme in the area of wheat and flour research and development and you may wish to contact them for information on their current research programme.
Question 3 – Could minimum micronutrient levels be established based on those found in stoneground flours at these standardised rates, which roller milling would need to replicate by technological adaption of techniques/processes, rather than fortification?
The levels of nutrients (except calcium) required by the Bread and Flour Regulations relate to those which would be present in flour at an equivalent to 80% extraction and was deemed to be appropriate to meet the needs of the UK population. The Agency has not therefore considered whether the minimum nutrient levels found in stoneground flours could be applied. If flour already contains the nutrients at the levels required then there will be no need to add them separately. The legislation does not specify techniques to be used only that the quantities should be present in the specified amounts and if not then they should be added in specific forms laid down by the regulations. If conventional roller mills were able to use techniques employed in mills producing stoneground flour to reach the regulatory nutrient levels required without the need to restore or fortify then the Regulations would not prevent this. It is up to flour and bread manufacturers to consider how this could be achieved.
Question 4 – Are the fortificants currently used actually the most bioavailable forms?
The Bread and Flour Regulations 1998 prescribe the forms of the vitamins and minerals required to be added to flour, for example calcium carbonate and thiamin hydrochloride. It is for historical reasons why these forms of the vitamins and minerals were selected, and this aspect of the Regulations has not been formally reviewed since it was put in place.
Bioavailability refers to the biological availability of a nutrient to the human body and is influenced by many factors, including the body’s need for the nutrient and the form of the nutrient in foods. For some nutrients, such as iron, the body’s need for the nutrient is the major determinant of nutrient uptake. While the prescribed forms of iron, calcium, thiamin and niacin that are required to be added to flour in the UK may not be the most bioavailable forms of these nutrients, they are relatively bioavailable and their properties make them suitable for use as fortificants in flour (for example, they are relatively heat stable and do not cause unacceptable changes to the sensory properties of the food).
In relation to iron, some questions have been raised about the suitability of elemental iron as a fortificant in foods. As noted in Question 1, SACN is currently considering iron fortification and its contribution to iron status. Similar questions have not been raised about the bioavailability of the other three micronutrients.
Question 5 – Could bread baking methods be used to make the intrinsic micronutrients more bioavailable? There is some research that shows bread made using longer fermentation with sourdough cultures can increase bioavailability of certain micronutrients.
Bread baking methods may influence the bioavailability of the intrinsic micronutrients in the food. Processes such as milling, soaking and fermentation of some foods helps to reduce levels of phytic acid, which in turn may increase the bioavailability of some nutrients. However, as stated by Poutanen et al (2009)4 “the results so far about the effects of sourdough and cereal fermentation are scarce”, so more research is required in this area.
As you will be aware, the method used to make bread is at the discretion of the manufacturer and is not regulated by Government. Therefore, manufacturers may choose to experiment with different methods to increase the nutrient content of their bread products. Though, as a starting point, it is important that the nutrient content of the wheat flour used to make the bread is sufficient.
I hope you find this information useful.
1) Henderson L, Irving K, Gregory J, Bates CJ, Prentice A, Perks J, Swan G & Farron M. National Diet and Nutrition Survey: adults aged 19 to 64 years. Volume 3: Vitamin and mineral intake and urinary analytes. TSO (London: 2003)
2) Gregory J, Lowe S, Bates CJ, Prentice A, Jackson LV, Smithers G, Wenlock R & Farron M. National Diet and Nutrition Survey: young people aged 4 to 18 years. Volume 1: Report of the diet and nutrition survey. TSO (London: 2000)
3) UK Dietary Reference Values: Department of Health. Report on Health and Social Subjects 41: Dietary Reference Values for Food Energy and Nutrients for the United Kingdom. Report of the Panel on Dietary Reference Values of the Committee on Medical Aspects of Food Policy. HMSO (London: 1991)
4) Poutanen K, Flander L, Katina K. Sourdough and cereal fermentation in a nutritional perspective. Food Microbiology 2009; 26, 693-99.
While the Real Bread Campaign has a position on flour 'fortification' in general, it does not have one specifically on the addition of folic acid.
The mandatory addition of synthetic folic acid to flour in an attempt to compensate for a lack of naturally-occurring folates in some people's diets is a complicated and contentious issue, with serious implications if it is or isn't implemented.
Sadly, lack of funding means that the Real Bread Campaign is not able to dedicate the time necessary to research this issue fully enough to make an appropriately-considered contribution to the debate.
The UK government and devolved administrations launched an open consultation seeking views on the proposal to introduce mandatory addition of folic acid to flour, running until 9 September 2019.
Campaign co-founder Andrew Whitley published the article 'Folic acid in our flour – food sense or counsel of despair?' on his Breadmatters website.
On 30 June, Lord Rooker introduced a House of Lords Bill to amend the Bread and Flour Regulations 1998 to require flour to be fortified with folic acid.
You can read the progress of this Bill here.
The Department of Health deferred making a decision on the possibility of making the addition of folic acid to flour mandatory. You can read their statement here.
On 6 November, the House of Lords held a short debate on the possibility of adding folic acid to flour.
On Monday 19 October 2009, in a letter to the Chief Medical Officer of England (CMO) the Food Standard Agency (FSA) re-iterated its earlier advice to implement mandatory fortification of all UK milled flour (except wholemeal) with 300µg folic acid (a synthetic form of the B vitamin folate) per 100g.
Here are links to some relevant information and articles:
Commentary. Fortification. Folic acid and spina bifida Is it safe? Is it wise? Is it right?, World Nutrition, March 2013
Folic acid and colorectal cancer risk: Review of recommendation for mandatory folic acid fortification, SACN, 19 October 2009
Improving folate intakes of women of reproductive age and preventing neural tube defects: practical issues, FSA board paper, June 2007
Eatwell (FSA) information on folic acid and folate
FSA general information on folic acid fortification, with further links
Options to increase folate intakes of young women Soil Association response to FSA consultation March 2007
The folate debate, Doves Farm, 16 December 2009