The letter was sent to the PM the same day the FSSAI published a press release detailing its plan to get residents of Chandigarh to "eat right, eat fortified" in order to combat malnutrition.
Last month, SJM called for the Central Bureau of Investigation (CBI) to launch an inquiry into the regulatory body regarding its recent notification on food fortification standards, in which the regulatory body pushed for national adoption of its updated guidelines.
These included the fortification of salt with iodine, and milk and edible oils with vitamins A or D, as well as the fortification of other staple foods such as vanaspati, atta, maida and rice.
SJM raised concerns over the possibility of 'mandatory' fortification, saying it could lead to harmful synthetic vitamins and nutrients being ingested on a large scale, instead of health benefits for the general public.
The organisation even called a press conference on August 20 in New Delhi, attended by industry representatives, nutrition experts, doctors, food scientists, and agricultural professionals, who unanimously chastised the FSSAI's attempt to implement food fortification on a national level as 'illegal'. They also alleged that the regulator was acting under pressure from MNCs.
Although the notification does not mention that the FSSAI's food fortification guidelines are to be mandatory, SJM's convenor Ashwani Mahajan believes CEO Pawan Agarwal has been pressuring SMEs to make food fortification compulsory.
All India Food Processors' Association president Subodh Jindal told the press he was suspicious because to his knowledge, the FSSAI had consulted with a number of foreign MNCs but ignored millions of local SMEs, while agricultural business expert Vijay Sardana said SMEs would be "pushed out of the market" because the FSSAI's proposed standards were impossible for them to follow.
Nutrition expert Arun Gupta said food fortification was not cost-effective, and the higher prices of fortified foods would likely make them inaccessible to the poor, who needed it most.
The letter of their discontent
In SJM's letter to the PM, the organisation claimed that the country's Ministry of Women and Child Development had held a national consultation on mandatory fortification of staple foods in New Delhi on August 24, saying it was "concerned and pained" over "decisions that will influence the lives of millions of poor Indians and have potential adverse effects for the national economy".
It said "the consultation had important presentations by stakeholders with a conflict of interest in promoting fortification, including those by the Global Alliance for Improved Nutrition (GAIN) and the food industry, while national academia and researchers with experience in this field were conspicuous (in) their absence".
It went on to urge the PM to instruct industry not to make any decisions until several concerns had been "satisfactorily addressed".
The first issue highlighted was the lack of a mechanism or safety net for the "identification of individuals in whom fortified micronutrients may prove harmful — for example, iron in subjects with haemoglobinopathies or thalassemia".
SJM suggested such individuals should be allowed "access to alternate non-fortified staple foods, and financial compensation for any harm caused due to mandatory fortification".
It then raised the "real possibility" of "harm due to over-dosage from several concurrent intervention, like iron supplementation under the Anaemia Mukt Bharat Programme and multiple iron-fortified foods, and mega-dose vitamin A supplementation and vitamin A-fortified oil".
It also said "scarce resources for logistics, manpower and finances will be wasted by duplicating the same intervention through different means".
Additionally, SJM questioned the purported health benefits of mandatory food fortification for the Indian population, saying they were "based on crude guesstimates of micronutrient deficiencies from old data in deprived settings".
It referred to the Ministry of Health and Family Welfare's Comprehensive Child National Nutrition Survey, which is expected to provide estimates of key micronutrient deficiencies on a national level for the first time, advising the government to wait for the report before making a "robust, evidence-informed decision".
SJM also named parties it suspected as having a conflict of interest: Tata Chemicals, GAIN, the Bill and Melinda Gates Foundation (BMGF), PATH, the Clinton Health Initiative, World Bank, the UN's World Food Programme (WFP), the WHO, and UNICEF, all of which SJM claimed were "known to have vested interests in fortification".
As such, it said the "current push to fortification is more a commercially driven one", encouraging the government to assess which party would benefit, and warning that it was "inevitable that most of the technology and basic raw materials will be imported, which will corrode the national economy and sustainability".
SJM added that mandatory fortification would affect SMEs that lack the novel technology and resources needed to comply with such regulatory requirements, and "take away the constitutional right of individual consumers to choose the foods they wish to consume".
It further said: "The stakeholder perspective on such crucial decisions has been totally ignored. The usual and cheaper sources of some micronutrients (such as) vitamin D are of animal origin. Mandatory intake of such ingredients would be in severe conflict with the cultural beliefs and practices of vegetarians, and has the potential to escalate into law and order issues."
SJM ended the letter by saying: "We believe that a consensus decision should only be arrived at after all national stakeholders participate, including experienced academia — particularly those opposing mandatory fortification."
Continuing the "fight"
Speaking to NutraIngredients-Asia shortly after sending the letter, Mahajan said, "First of all, the FSSAI does not have the mandate to make it compulsory to fortify foods.
"Secondly, nowhere in the world do you have mandatory food fortification with vitamins A or D. The human body lacks the receptors to absorb synthetic vitamin, so eating such foods could cause bodily harm — this is the opinion of the health experts expressed at our press conference."
Referring to national programmes already in place to provide iron and folic acid to women, he added that mandatory fortification meant "giving such nutrients to the whole population, whether they need it or not".
"Excessive nutrients can also cause damage to overall health. Nowhere in the world is such fortification (with vitamins) mandatory, so why should India do it? The people trying to make it mandatory are playing into the hands of the vitamin 'cartel'."
He further alleged that the FSSAI had "joined hands with MNCs like BMGF and their associated organisations", warning that SJM was "keeping a close eye on them all".
SJM's suspicion, he said, was due in part to the FSSAI's apparent silence on more vital micronutrients.
"Folic acid is required but they are not talking about it — they are not talking about what is required, but are trying to push what is not required. That's the reason we are calling for a serious inquiry into the FSSAI.
"We will keep pushing for the CBI inquiry. There are very powerful people behind the FSSAI, but for the health and welfare of the people, we will continue our fight."
The fortification scheme was first unveiled in 2016 as the FSSAI and the government sought to tackle India's systemic problem of micronutrient deficiencies.