Innspill til NNR 2022 – Nordic Nutrition Recommendations

Vi har sendt flere innspill til flere kapitler i NNR 2022 – Nordiske ernæringsanbefalinger 2022, som etter planen kommer sommer 2023. NNR 2022 er et forarbeid, eller vitenskapelig grunnlag, til fellesnordiske kostholdsråd.

Nå er arbeidet med kostrådene nesten ferdig, og arbeidsgruppen i Nordisk ministerråd har sendt utkastet på høring. Lenke er her Les også: Helsedirektoratets nye kostråd 2023 anbefaler å halvere kjøttforbruk. Dette vil gi bedre matberedskap i Norge

Lege- og ernæringsforeningen Mat for helsen har sent følgende innspill til NNR 2022.

I Norge hadde Helsedirektoratet et informasjonsmøte angående kapittelet Food consumption and environmental sustainability considerations in the Nordic and Baltic region. Dette kapittelet er eneste (i tillegg til et til) som omtaler bærekraft. Alle de andre kapitlene ser kun på sammenheng mellom kosthold/ernæring og helse.

Norsk kjøttindustri har fremmet flere protester mot dette kapittelet, i og med kapittelet er kritisk til husdyrhold. Leder og professor Rune Blomhoff hadde en forklaring på Helsedirektoratets dialogmøte 12.januar.

Food consumption and environmental sustainability considerations in the Nordic and Baltic region

The chapter Food consumption and environmental sustainability considerations in the Nordic and Baltic region has been debated in Norwegian media a lot. Here is our respons to this chapter https://www.helsedirektoratet.no/

GENERAL COMMENTS

Communication about nutrients and animal products is important

The majority of people believe that animal products are natural and necessary to get enough nutrients. People do not know how much protein they need. Communication such as “10 – 20 percent of daily energy intake” is not optimal. Despite the fact that people in the West consume almost twice as much protein as needed, many are concerned that they ayre getting enough. This will harm health and sustainable health choices.

Chapter could therefore consider looking at communication as an important solution for changing eating habits and knowledge about. Communication about the following is important:
-nordic citizens get much more protein than human body needs,
-not all «lost» protein from animal foods must be replaced (with the same amount of plant protein) from a health and nutritional point of view.
• None of the essencial amino-acids must be replaced.
• Just with milk, cheese and meat, people get twice as much as they need.

Generic marketing of dairy and meat is an important obstacle

Generic promotion/advertising for meat and dairy products should be problematized to change dietary habits (for example, Matprat and melk.no in Norway, they spend approx. NOK 79 an NOK 30 million respectively on generic promotion). Their business is an important factor that contributes to increased consumption of these products. It has been documented that generic advertising works and increases consumption.
Source: The National Economic Contribution of Agricultural Advertising And Promotion, Report to CRMC Group, LLC (FABA), April 2017 https://test-portal.nifa.usda.gov/web/crisprojectpages/1013889-world-commodity-supply-chains-and-agricultural-commodity-marketing-and-promotion.html

se page 68 – 71. Norwegian report for Norwegian Environment Agency from NIBIO. Oppdragsrapport. Overgang fra rødt kjøtt til vegetabilsk og fisk: Klimakur 2030, utgitt:01.03.2020 av NIBIO https://www.miljodirektoratet.no/publikasjoner/2020/mars-2020/overgang-fra-rodt-kjott-til-vegetabilsk-og-fisk/ pdf here https://www.miljodirektoratet.no/globalassets/publikasjoner/m1497/m1497.pdf

Rune Blomhoff NNR 2022 skjermdump-kjøtt 12.januar 2023

SPESIFIC COMMENTS

To food groups 8 and 9 (meat and dairy)

Meat

After the lines 2066 – 2070 I suggest folowing text:
“However, existing data and rough estimates of protein intake and essential amino acid intake show that the intake of dairy products can at least be halved compared to current intake. It is not necessary, from a health and nutritional perspective, to replace all the reduced/”lost ” amount of protein with plant sources. There are no health benefits to maintaining current protein intake at the same level as today.”

Dairy

After lines 2225 – 2228, I recommend writing the following:
“Nevertheless, existing data and rough estimates of protein intake and essential amino acid intake show that the intake of dairy products can be at least halved compared to current intake. It is not necessary to replace all the reduced/”lost” amount of protein with plant sources.”

Explanation about meat and dairy:

There is a clear difference between protein needs from a HEALTH point of view and today’s ACTUAL INTAKE. From a health and nutrition perspective, northern or Baltic citizens do not need to maintain their current protein and amino acid intake at the same level as today.
The need for protein is no more than 0.8 grams of protein per kilogram of normal body weight. A man of 70 kilograms needs about 56 grams of protein per day. A woman weighing 60 kilograms needs 48 grams per day.

Norwegians eat an average of 96 – 100 grams of protein per day (Norkost 3, Matprat https://www.matprat.no/artikler/ernaring/proteiner/ and https://www.helsedirektoratet.no/rapporter/utviklingen-i – Norwegian diet).
The lysine requirement is approximately 30 – 38 milligrams of lysine per kilogram of body weight per day. Thus, an adult man of 70 kilos needs approx. 2.6 grams of lysine per day (https://apps.who.int/iris/bitstream/handle/10665/43411/WHO_TRS_935_eng.pdf).

Norwegians consume more than twice as much lysine as the human body needs. Only with cheese, milk and meat, not including other food. helsedirektoratet.no/rapporter/utviklingen-i-norsk-kosthold/
Meat and dairy are not the solution for micronutrient intake – neither “natural” nor reliable source of micronutrients.
Calcium, vitamins B12 and D, and iodine and many other micronutrients are added artificially to animal feed concentrates (see Raw material consumption here: landbruksdirektoratet.no/nb/statistikk-og-utviklingsstrekk/utvikling-i-jordbruket/ kraftforstatistikk).
In northern countries, deficiency/suboptimal intake of vitamin D and B12 and iodine is common (not among vegans). Despite excessive consumption of animal products.

Sources:
• https://www.helsedirektoratet.no/rapporter/vitamin-d-i-norge-behov-for-tiltak-for-a-sikre-god-vitamin-d-status/
-https://apps.who.int/iris/handle/10665/136908
• https://ods.od.nih.gov/factsheets/VitaminB12-HealthProfessional/#h5

New pandemy and antibiotika-resistance

Industrial farming and demands for more animal protein are important contributors to the development of new zoonoses and pandemics, as well as antibiotic resistance.
https://link.springer.com/article/10.1007/s10640-020-00484-3-
https://www.unep.org/news-and-stories/press-release/unite-human-animal-and-environmental-health-prevent-next-pandemic-un

As replacement, plant based meat and plant milks should be recommended

Plant milks, especially oat, fortified with iodine, vitamin D and B12, and calcium, and plant meats are both healthier and more land-areal-effective and better for climate then meats and dairy.
• https://www.pnas.org/doi/10.1073/pnas.2120584119
https://doi.org/10.1016/j.fufo.2022.100174
• https://doi.org/10.1016/j.jclepro.2021.126447
Reports from Norway
https://www.mattilsynet.no/mat_og_vann/produksjon_av_mat/frukt_bar_gronnsaker_og_korn/analyser_av_naeringsstoffer_og_uonskede_stoffer_i_plantebaserte_middagsprodukter_og_drikker_2021.45515

Innspill til det totale utkastet mai 2023

From Physicians’ and nutrition association Food for health (Lege- og ernæringsforeningen Mat for helsen)

General comment

Do we need to replace meat or animal protein with legumes or any other sources for protein (or any other nutrients)?

You write on page 61, 62 and 138 and 140:
“To minimize environmental impact, meat consumption should be replaced with increased consumption of plant foods such as legumes.” Why do we need to replace meat?

I suggest to consider following:

1-Contribution of meat to the total intake of f.ex. protein and Iron: How much, or how big part of the total intake of f.ex. protein or iron, comes from meat?

2-Actual intake of protein versus requirement: How much protein does the population consume, and how much protein do we humans need/what is the requirement for protein?

For ex. Norwegian nationwide dietary survey Norkost 3 shows, see table 25b on page 44, shows that meat contributes only with 27% of the total intake of protein, and only with 20 % of the total intake of Iron.

The same survey, Norkost 3, attachment nr. 7.7 on page 66 and 7.8 on page 67 shows that in genereal, the public consumes 80 (women) – 112 (men) gram protein a day. It is almost twice as much as human body needs (0,66 gram x body weight a day).

Because the public in North consumes much more protein that necessary, at least 50 – 90 % more, it is not nesessary to replace meat with any spesial foods.

Men consumes more than enough iron.
Women consumes little bit less iron that recommended.
Coarse grains, and not meat (especially not white meat) are the biggest sources of iron in our diet.
So, it is not necessary to replace meat reduction with anything.

Source: Norkost 3. A nationwide dietary survey among men and women in Norway aged 18-70, 2010-11. The University of Oslo, the Norwegian Food Safety Authority and the Directorate of Health.

Specific comment

Vitamin B12

I suggest to write “if they do not take supplement of vitamin B12” in this sentence

“The ones who omit or restrict animal products in their diets, as vegetarians and vegans, are destined to become vitamin B12 deficient.”

Protein

I suggest to write

“Todays recommendations for intake of protein for vegetarians and vegans are the same as for the general population, because the evidence suggests a similar total protein requirement to those following western vegetarian diets in general.” in the end of the article. Sources:

Mariotti F, Gardner CD. Dietary Protein and Amino Acids in Vegetarian Diets-A Review. Nutrients. 2019;11(11):2661. Published 2019 Nov 4. doi:10.3390/nu11112661

Quoted: “Therefore, the evidence suggests a similar total protein requirement to those following western vegetarian diets in general [41]”.

“In developed countries, plant proteins are mixed, especially in vegetarian diets, and total intake of protein tends to greatly exceed requirement. This results in intakes of all 20 amino acids that are more than sufficient to cover requirements. In the EPIC-Oxford study, amino acid intakes were estimated in both meat-eaters and vegetarians [24]. “

(24. Schmidt J.A., Rinaldi S., Scalbert A., Ferrari P., Achaintre D., Gunter M.J., Appleby P.N., Key T.J., Travis R.C. Plasma concentrations and intakes of amino acids in male meat-eaters, fish-eaters, vegetarians and vegans: A cross-sectional analysis in the EPIC-Oxford cohort. Eur. J. Clin. Nutr. 2016;70:306–312. doi: 10.1038/ejcn.2015.144.)

2. Melina V, Craig W, Levin S. Position of the Academy of Nutrition and Dietetics: vegetarian diets. J Acad Nutr Diet. 2016;116:1970-1980 Quoted: “Protein Vegetarian, including vegan, diets typically meet or exceed recommended protein intakes, when caloric intakes are adequate.6-8