The Fortification Fallout: Examining India’s Controversial Nutrition Strategy 

The subject of mandatory or compulsory food fortification in India, has gained traction and become controversial in recent times. India’s position of 107 out of 121 on the Global Hunger Index 2022 has highlighted the prevalence of child malnutrition, nutrition deficiency, and hunger crisis in the country. The index takes into account factors such as stunting, wasting, and mortality among children, as well as caloric insufficiency among the general population. While the government of India has taken several steps to address these issues, food fortification has emerged as a widely-discussed solution to tackle malnutrition in the country. 

In 2018, the Food Safety and Standards Authority of India (FSSAI) introduced the Food Safety and Standards (Fortification of Foods) Regulations 2018, which laid down standards for fortification and labelling. These regulations mandate the fortification of edible oil and milk with Vitamin A and/or Vitamin D 33, and salt with iron and iodine to produce Double Fortified Salt (DFS). Wheat (both maida and atta), and rice , are to be fortified with iron, folic acid, and vitamin B12, along with optional vitamins like Zinc, Vit A, Thiamine, Riboflavin, Niacin, and Pyridoxine. The regulations also cover the fortification of processed foods such as cereals and bakery products. 

Currently, fortification of foods is not compulsory, except for iodised salt. However, the government plans to make fortification mandatory for packaged edible oil and milk. The FSSAI has issued guidelines for the mandatory fortification of these products, and the Fortification of Foods Regulations 2018 provide a framework for mandatory fortification of other staples, subject to government direction. Following the guidelines for mandatory fortification of edible oil and milk from the FSSAI, the government has already expressed its intention to introduce compulsory iron fortification of rice in all major food programmes.

The Indian government sees mandatory food fortification as a promising solution to address malnutrition in the country. However, a letter dated August 2, 2021, addressed to Ashok Kumar Mishra, the assistant director of the Food Fortification Resource Centre (FFRC), which regulates food fortification under the FSSAI, presents a different perspective. The letter, signed by people and organisations including medical experts and nutritionists, opposes the synthetic fortification of foods such as rice with iron. The validity of this criticism against mandatory food fortification is a topic of debate. 

Mandatory food fortification: A blanket approach?

Experts are criticising India’s ‘Blanket Approach’ to addressing the complexity of malnutrition in the country. The government has started including synthetically-fortified foods in all its public food programmes, like the PDS (Public Distribution System), ICDS (Integrated Child Development Scheme), PMGKAY (Pradhan Mantri Garib Kalyan Anna Yojana, a COVID-19-related food scheme), and MDMS (Mid Day Meal Scheme renamed as POSHAN, which provides meals to school children throughout India). As a result, the majority of the population, who rely on India’s food security programmes, are exposed to these foods. 

Advocates of the right to food have raised concerns about several risks associated with large-scale, near-mandatory food fortification programmes. These risks include threats to the livelihoods of small-scale producers and processors, public health risks such as over-reliance on a few food groups of cereals for vitamins and minerals, and irreversible market shifts that could make people dependent on ultra-processed foods manufactured by corporations instead of natural and diverse foods produced by local communities. 

Mandatory food fortification could have a significant economic impact. Many small players like the Atta Chakkis, oil mills, and rice mills could be adversely affected, leading to poverty and malnutrition. Jimena Monroy-Gomez, Technical Nutrition Associate at Sight and Life in Switzerland, commented on the incapability of Small and Medium Enterprises (SMEs) to follow food fortification practices and the resulting livelihood risks.  She said, “The lack of relevant data to design context-appropriate food fortification strategies is an indirect obstacle to SMEs engaging in food fortification practices. This data gap limits the opportunity to guide SMEs to implement food fortification activities according to local needs. Limited access to sustainable finance is also a crucial barrier that prevents SMEs from implementing innovations or improving their capacity to produce more fortified foods. The cost of manufacturing fortified food compared to non-fortified food can be <1 per cent up to 1.33 per cent higher for wheat flour, milk, and edible oil, and up to 4.5 per cent higher for some varieties of rice. Moreover, the lack of technical knowledge limits SMEs’ ability to improve their operations, revenues, and shelf storage process.”

Additionally, it is worth noting that these food programmes are legally entitled to the majority of Indians. However, no independent risk analysis has been conducted in the country, and as of 2023, evaluation studies for the 3-year pilot programme on fortified rice in PDS, initiated in 2019 by the government in partnership with certain NGOs, including those linked to the nutraceutical industry, are still not available. Such NGOs have been doing their own evaluation studies of their own fortification interventions in different states. These evaluations where they exist, have been found to be highly biased, giving glowing reviews to their own programmes. 

One significant health risk of mandatory food fortification, as per FSSAI’s own regulations, is that iron-fortified foods cannot be given to patients who are contraindicated to eat iron. Iron can be toxic to those suffering from infections like malaria and tuberculosis, or hemoglobinopathies like thalassemia and sickle cell anaemia. However, fact-finding visits by the Alliance for Sustainable & Holistic Agriculture (ASHA-Kisan Swaraj network) and Right to Food Campaign teams to Jharkhand and Chhattisgarh revealed that such patients were not being screened and were indiscriminately being fed iron-fortified rice, as the central authorities had not established clear protocols to protect such patients. Despite such glaring policy gaps, the programme is being rapidly scaled up across the country. 

“High body iron stores have been associated with an increased risk of non-communicable diseases (NCDs) like diabetes, hypertension, or dyslipidemia in adults and adolescents. The potential escalation of  NCD risk should be an additional consideration when evaluating the benefits and harms of multiple public health interventions to enhance iron intake for addressing anaemia. A rational approach that improves erythropoiesis in those who need it, through a wide approach of calibrated intake of diverse diets along with physical activity and a  clean environment, is likely to benefit populations much more than single nutrient initiatives. This is especially relevant to iron supplementation and food iron fortification programmes that are directed at Indian children. This should be considered when evaluating the benefits and harms of enhancing iron intake in anaemia prevention programmes,” said Dr Tinku Thomas, Professor & Head, Dept. of Biostatistics, St. John’s Medical College, Bangalore. 

The large-scale near-mandatory food fortification seems to convey the message that the government expects poor Indians to receive the bulk of their nutrition through one or two chemically fortified cereals like rice or wheat. However, similar policy and programmatic emphasis is not being given to balanced and diverse diets, which are essential for adequate caloric intake and for essential proteins, fats, vitamins and minerals. Although the FSSAI has acknowledged that dietary diversity is the ‘best choice’ to address malnutrition, and that fortification is a ‘complementary strategy,’ it is clear that corporate-led fortification is becoming the main policy thrust, while holistic, balanced natural diets, produced and processed by communities themselves, are not receiving the same attention. 

Where does the origin of this controversy lie?

In February 2023, the Alliance for Sustainable & Holistic Agriculture (ASHA)  published a report titled “Do India’s Food Safety Regulator (FSSAI) and Indian Citizens Need Saving From (Foreign & Indian) Private Players Behind Food Fortification Initiatives? – A Report on the Objectionable Conflict of Interest that Pervades India’s Food Fortification Public Policies & Programmes.”  The report raises concerns about potential conflicts of interest in decision-making around food fortification, which is currently receiving unprecedented policy support in India as the silver bullet solution to malnutrition and anaemia. The report focuses on the industry-funded, founded, and industry-led body called the Food Fortification Resource Centre (FFRC), which holds a seat within the FSSAI and has influence over state programme implementation, funding, and evaluation. According to the ASHA report, the FFRC’s members are promoters of fortification and are linked to nutraceutical and food corporations that stand to benefit financially from a push towards food fortification in India. 

As per the report by ASHA, the FFRC is an industry body comprising members who function as lobby groups to advocate for fortification-friendly policies in India. Despite the FFRC’s claim of being merely a resource centre, its significant influence and role in policy-making are apparent. The report provides a detailed account of the corporate actors and NGOs within the FFRC, as well as their financial interests in fortification, based on publicly available information about these entities. 

Some of the members of the FFRC include the Tata Trusts, the founding partner of the FFRC with links to the Tata Group, as well as Wella Nutrologicals and Tata Global Beverages. All of these members have a financial interest in fortification since they produce nutraceuticals used in fortification and manufacture fortified food products. Another significant partner, GAIN, has been referred to as a lobby group for nutraceutical and big food corporations such as BASF, DSM, and Cargill. Additionally, GAIN operates its own premix facility to produce and supply fortified foods to international markets. 

PATH, a company that produces vaccines, drugs, and devices, has a proprietary fortified rice technology called Ultra Rice, which is currently being used in government mid-day meals in some states. The report highlights several other examples where corporate actors have a financial stake in promoting fortification in India. The oversized role of the Gates Foundation within the FFRC is particularly noteworthy, including the presence of Bill Gates himself, during the centre’s launch. Furthermore, various NGOs linked to corporations within the FFRC are being financially supported by the Gates Foundation.

Kavitha Kuruganti, Founder Convenor, ASHA, said, “Regulatory decision-making by agencies like FSSAI should include a needs, benefits, and alternatives analysis which will lead to lasting, sustainable solutions. Regulation should also prevent conflict of interest, especially of industry entities and keep out Bill & Melinda Gates Foundation, GAIN, and other such entities fully. Government should promote awareness, working with civil society and others who are working on low-cost, sustainable solutions such as agro-ecological farming, promotion of uncultivated foods, setting up of kitchen gardens, popularising bran in diet, and revival of nutrition-rich diverse varieties of crops. Instead of pushing mandatory food fortification (including rice and oils) of doubtful benefit and potential harm, launching a major awareness campaign on the importance of micronutrients and their availability in millets, microgreens, vegetables, and fruits as awareness itself can alter behaviour beneficially.”

This report also highlights the issue of private interests being housed within a regulatory body like the FSSAI, urging that their sphere of influence should be checked in matters of public health and food safety in accordance with India’s laws. Additionally, the report notes that fortification is often portrayed as a silver bullet solution without considering  critical perspectives and evidence. Finally, it is noted that the mandates of the FSSAI and the FFRC are divergent, with the former being guided by principles of food safety that include independent and transparent risk assessment, public consultations and protection of consumer choice and interest, among others. 

Mansi Jamsudkar


Image credit- shutterstock

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