Review of salt iodisation legislation in the region Achieving Universal Salt Iodisation for Optimal Iodine Nutrition UNICEF, IGN, GAIN, MI EAP Regional Meeting 12-14 October, Bangkok #commit2USI Review of salt iodisation legislation in the region Karen Codling IGN Regional Coordinator for Asia & Pacific UNICEF Consultant

Information on legislation from UNICEF programme officers Background 140 countries have USI programmes;1 it is unknown how many of them have salt iodisation legislation Review of salt iodisation legislation undertaken by UNICEF for the Southeast Asia and East Asia and Pacific region in 2012, updated 2015 Information on legislation from UNICEF programme officers 1. Iodine Global Network (2014). Status by region, 2014. Available from http://ign.org/p142001046.html (Quoted in GAIN. Fortifying our Future: A snapshot report on food fortification) EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Current legislation Situation in 36 countries reviewed (Rep of Korea excluded) Existing, draft or planned legislation in 22 countries No legislation in 15 countries DPRK Malaysia (sub-national only) Maldives Several Pacific Islands (Cook Is, Kiribati, Marshall Is, Micronesia, Nauru, Niue, Palau, Samoa, Tonga, Tuvalu, Vanuatu) EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Timeline of salt iodisation legislation Singapore (1988) Bangladesh (1989) 1990-1994 Laos (1991) China (1994) Indonesia (1994) Thailand* (1994) 1995-1999 Papua New Guinea (1995) Philippines (1995) Fiji (1996) Nepal (1996) India* (1998) Myanmar (1998) Malaysia (1999)** Sri Lanka (1995)* Vietnam* (1999) 2000s Brunei (2000) Cambodia (2003) Mongolia (2003) Afghanistan* (2007) Solomon Islands (2010) Singapore & Brunei have food standards permitting voluntary fortification, rather than salt iodisation legislation *Initial legislation. These countries now have new legislation in force. ** State legislation NB. Bhutan, Pakistan and Timor Leste have “parliamentary decision” or draft legislation

mechanism of salt iodisation legislation EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Stand alone legislation includes implementation rules Coordination mechanisms Registration/licensing of iodised salt producers Control of imports Control of transport of non-iodised salt Differentiating between industrial and food-grade salt Public information Internal quality assurance External quality assurance Special allowances for small producers Penalties “Stand alone” legislation has a propensity to establish salt iodisation as a vertical programme EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Mandatory or voluntary? “The fundamental distinction between mandatory and voluntary regulation as it applies to food fortification is the level of certainty over time that a particular category of food will contain a pre- determined amount of a micronutrient. By providing a higher level of certainty, mandatory fortification is more likely to deliver a sustained source of fortified food for consumption by the relevant population group, and, in turn, a public health benefit” (WHO/FAO Guidelines on food fortification with micronutrients) EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Mandatory or voluntary? “In one decade, countries with mandatory legislation had a greater increase in household coverage (from 49% to 72%) than countries with voluntary iodisation (40% to 49%)” 1. Horton S., Mannar, V. & Wesley, A. (2008) Micronutrient Fortification (Iron and Salt Iodization) Copenhagen Consensus Best Practice Paper 2008. Available at: http://www.copenhagenconsensus.com/research/best-practice-papers/micronutrient-fortification Ref: Horton S., Mannar, V. & Wesley, A. (2008) Micronutrient Fortification (Iron and Salt Iodization) Copenhagen Consensus Best Practice Paper 2008. EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Mandatory or voluntary? Salt iodisation is mandatory in all countries with existing legislation except: Brunei & Singapore – have voluntary food regulations that allow salt iodisation Viet Nam – current legislation encourages iodisation but does not mandate it. New mandatory legislation is currently being drafted. EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Malaysia experience: importance of mandatory legislation Ref: Selamat et al. Iodine deficiency status and iodised salt consumption in Malaysia: findings from a national iodine deficiency disorders survey. Asia Pac J Clin Nutr. 2010

Objective of salt iodisation legislation prohibits non-iodised salt or allows only iodised salt requires the iodisation of all salt within the scope of the legislation guides the production of iodised salt sets standards if salt is iodised (voluntary) EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Objective of salt iodisation legislation Non-iodised salt banned or only iodised salt allowed All salt must be iodised Guides production of iodised salt Bangladesh Bhutan (interpreted) Afghanistan Cambodia Laos Indonesia China Nepal Fiji Philippines India Thailand Malaysia Timor Leste (draft) Mongolia Viet Nam (draft) Myanmar Voluntary iodisation Pakistan (draft) Brunei Papua New Guinea Singapore Solomon Islands Viet Nam (current) Sri Lanka EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Scope of salt iodisation legislation WHO, UNICEF and the ICCIDD (now the Iodine Global Network) define universal salt iodisation as “the iodisation of all human and livestock salt, including salt used in the food industry.1 Recent, updated guidelines for the fortification of food grade salt with iodine emphasise the importance of fortifying salt in food processing.2 WHO, UNICEF & ICCIDD. Assessment of iodine deficiency disorders and monitoring their elimination: A guide for programme managers. Third Edition. WHO 2007. WHO. Guideline for fortification of food-grade salt with iodine for the prevention and control of iodine deficiency disorders. Geneva, WHO 2014 WHO, UNICEF & ICCIDD. Assessment of iodine deficiency disorders and monitoring their elimination: A guide for programme managers. Third Edition. WHO 2007. WHO. Guideline for fortification of food-grade salt with iodine for the prevention and control of iodine deficiency disorders. Geneva, WHO 2014 EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Scope of salt iodisation legislation Universal salt iodisation legislation Food processing salt specifically included Food processing salt excluded Salt for animals excluded Afghanistan Cambodia Bangladesh India Bhutan (interpreted) China Malaysia Mongolia Indonesia Pakistan (draft) Sri Lanka Fiji Philippines Laos Myanmar Thailand Imported salt excluded Nepal Timor Leste (draft) None Papua New Guinea Solomon Islands EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Salt iodisation standards Majority set in separate regulation, rather than Law/Act Wide range of iodisation standards (15-70mg/kg) Standards higher than recommended in several countries Usually set standard at production level; some set more than one level & some did not specify at which level standard applies Some did not indicate maximum level EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Importance of legislation, in particular mandatory legislation Lessons learnt Importance of legislation, in particular mandatory legislation Political commitment necessary for legislation Legislation only effective if enforced; weak enforcement and low penalties are common Mechanism of legislation has implications for implementation and enforcement mechanisms  regulation under Food Act EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

Strongest legislation bans/only allows iodised salt Lessons learnt Strongest legislation bans/only allows iodised salt Setting conditions for salt iodisation hinders iodisation of all salt Scope of legislation is important; inclusion salt for food processing Levels of iodine in this region possibly too high; need to review in light of urinary iodine levels EAP Regional Workshop on ACHIEVING UNIVERSAL SALT IODISATION FOR OPTIMAL IODINE NUTRITION

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