The fortification of flour in the UK became established in the 1950s. The addition of calcium carbonate became mandatory in 1943 to increase calcium levels in the diet and throughout the 1940s to the end of food rationing in 1954 the milling of flour up to 80% extraction or higher was required by law in order to make full use of the nutritional value of the wheat grain.
In 1953 the milling requirement was removed, bread could again be made from flour of 70-72% extraction but it contained much lower levels of nutrient found in the germ and outer layers of the grain present in flour of 80% extraction. Regulations were introduced to restore the iron, thiamin and niacin lost in the milling process and continue the addition of calcium. The present regulations are to be found in Bread and Flour Regulations 1998.1
In early 2013 the Department of the Environment, Food and Rural Affairs (Defra) launched a consultation on the continued need for mandatory flour fortification. The last review was undertaken in 1981 when the Committee on Medical Aspects of Food Policy (COMA) recommended that the addition of iron, calcium carbonate, thiamin and niacin should no longer be required on the basis that dietary survey evidence indicated that intakes of these nutrients were adequate. The Government of the day ignored the advice.
In August 2013 the present Government published a summary of the responses made in the consultation and, once again, announced that the 1998 Regulations were to be left unchanged. The decision provoked little reaction, but was seen by some commentators as a missed opportunity to realign a part of the food system for good in favour of more nutrient dense food.2
It remains the case that all wheat flour (except wholemeal) produced in the UK is subject to legislation which requires calcium, iron, niacin and thiamin to be added at certain specified levels. In the case of calcium it is for fortification purposes while iron, niacin and thiamin are added to replace what is lost during the milling process.
2 The Bread and Flour Regulations 1998
The Bread and Flour Regulations 1998 prescribe3 the composition of flour derived from wheat and no other cereal. The addition of iron, calcium carbonate (chalk), thiamin (vitamin B1) and niacin to all wheat flour (except wholemeal flour) is required at the milling stage of processing flour as follows:
|Calcium carbonate||235 – 390 mg/100g flour|
|Iron||Not less than 1.65 mg/100g flour|
|Thiamin (Vitamin B1)||Not less than 0.24 mg/100g flour|
|Nicotinic acid or Nicotinamide||Not less than 1.60 mg/100g flour|
These nutrients must be added in one or more of the forms specified.
The requirement to add calcium carbonate does not apply to wholemeal flour, self-raising flour which has a calcium content not less than 0.2% and wheat malt flour.4 In the case of the remaining three nutrients (iron, thiamin (vitamin B1) and niacin) these must be naturally present in the prescribed quantities in wholemeal flour and in the case of other flours must be added where necessary.5
The Food Standards Agency has issued detailed guidance on the application of the 1998 Regulations.6
It is an offence for any person who is a manufacturer of flour to sell flour which does not comply with these requirements,7 punishable on summary conviction with a fine not exceeding level 58 on the standard scale.
The presumptions, defences and related matters contained in the Food Safety Act 1990 apply to the 1998 Regulations,9 including the extended meaning of 'sale', presumption that food is intended for human consumption, offence due to fault of another person and defence of due diligence.10
3 The Case for Fortification
The Scientific Advisory Committee on Nutrition (SACN) was asked to look at the impact of repealing the 1998 Regulations and in June 2012 produced a report: Nutritional Implications of Repealing the UK Bread and Flour Regulations. SACN undertook a modelling exercise using the latest data from the National Diet and Nutrition Survey to estimate the impact of nutrient removal from flour on nutrient intakes in all age groups.
SACN concluded that the impact of removing added thiamine and niacin would be small, these nutrients are widespread in the diet and clinical deficiency is rare. The impact of removing added calcium and iron would be greater, particularly for calcium, and it would have a greater impact on those whose intakes of calcium and iron are already low and a concern, namely older children and young adults, particularly women. SACN go on to state, however, that:
(I)ron in the form added to wheat flour (and in iron-fortified foods) is poorly absorbed and may be of little practical use in improving iron status, even in individuals with increased systemic iron needs. This is probably due to the low solubility and resultant low intestinal uptake of the iron salts used.11
On the way to reaching these conclusions, SACN highlighted a number of interesting points:
Total bread consumption shows a long-term decline in all age groups.
There is some evidence of a switch from white to brown, granary and wheatgerm breads, although the majority remains white.
The proportion of bread and flour products imported into the UK is minimal.
Only about 1% of domestic flour is imported.
The debate surrounding the repeal of the requirements to fortify flour look set to focus on the need for added calcium and whether this should be a voluntary or mandatory fortification. When first introduced in the 1940s the scarcity of dairy products was a part of the justification for the mandatory addition of calcium, but dairy products are now available in abundant supply.
2 Andrew Whitley, Bread and flour – the fig-leaf of fortification remains, Artisan Food Law Blog, 4 September 2013
6 Food Standards Agency, The Bread and Flour Regulations 1998 (As Amended): Guidance Notes, Version 1, June 2008
8 Currently £5,000
11 SACN, Nutritional Implications of Repealing the UK Bread and Flour Regulations, June 2012, page 9, para 25