Takaisin Nordic Nutrition Recommendations 2023, NNR 23 (Public consultation)


Nordic Nutrition Recommendations 2023, NNR 23 (Public consultation)


Nordic Council

General comments

Thank you for the opportunity to comment the NNR2023. The process of making new nutritional recommendations has been thorough, broad, and scientific. The public has had the opportunity to participate and follow the process.

The draft about new Nordic Nutrition Recommendations does not say anything about security of maintenance. As we have seen in last years, Covid-19 pandemic and war in Ukraine, every country needs to have a food chain of their own, especially here in Northern countries. Here in Finland, this is essential due to our very end location and long border line with Russia.

There are many good special features in Nordic farming and food production that should be recognized and acknowledged. For example, agriculture in Finland has adapted to northern conditions, long distances, and consumer wishes. Food is produced in a different way than in most other parts of the world, for example animal welfare is at a good level, and plant protection agents are used only sparingly and when necessary.

Considering the unique cultural, environmental, and agricultural characteristics of the Nordic region, the recommendations should aim to provide guidelines for a healthy and sustainable diet. Overall, organic farming should be better considered in this report due to its unquestionable long-term benefits for soil health, biodiversity, and sustainability. For example, guidelines could promote the consumption of locally grown, in-season, and organic produce. This can help reduce food production's environmental impact and promote regional biodiversity and vigor. Eating local in-season food is also often an economical choice.

As stated in the NNR2023 report, evaluating the food system is challenging because the processes are complex, uncertainties are significant, production methods vary, and the range of products is wide. In addition, MTK emphasizes that different evaluation perspectives can be in conflict with each other, for example in the case of cattle farming. Cattle farming can have challenges from a climate point of view, but on the other hand, the associated grass farming and especially grazing are clear strengths in terms of both climate and diversity. In addition, it is good to remember that livestock farming is also an efficient nutrient recycling through the utilization of manure.

In the Nordic nutrition recommendations local conditions for agricultural production must be considered. Animal husbandry is a major sector in Nordic agriculture because of the favorable climate conditions. In Nordic countries animal husbandry can be done sustainably, for example compared to areas where there is a shortage of water. A lot of sustainability work has already been done in the Nordic’s animal husbandry sector and work is ambitiously going-on to reduce the environmental impact further.

It is important to understand the food system as a whole. Versatile production, locality and security of supply are the cornerstones of the food system. The FAO published a policy brief of terrestrial animal source foods and their contribution to food security, sustainable agrifood systems and nutrition and healthy diets. FAO (2023) “Contribution of terrestrial animal source food to healthy diets for improved nutrition and health outcomes.” Available at: https://doi.org/10.4060/cc3912en

The Natural Resources Institute Finland has published report on sustainability of the Finnish cattle (milk and beef) which outlines well the Finnish manner of producing milk and beef. It is important to notice that production differs from country to country although Nordic countries also have similarities. Available at: https://jukuri.luke.fi/handle/10024/553105?show=full

MTK emphasizes that northern conditions strongly limit the possibilities of changing the food system. This applies especially to Finland. If population-level changes to the food system are desired, it will inevitably bring up new production uncertainties and risks, when, for example, the cultivation area of protein and oil crops would be greatly expanded. Considering the necessary crop rotation, the required area is significant and would expand production to areas that are not favorable for more demanding cultivation. MTK emphasizes that in all reviews and goals, the social and, above all, financial sustainability of the food system must be considered.

Specific comments:

• p. 20 Animal fat contribute is compared to sweets and sugar tough foods containing animal fat might contain some beneficial nutrients too, unlike sugar or sweets.
• p. 25 The paper focuses on global considerations and hence does not consider the local context in Nordic and Baltic countries. Nordic food production has many good features that cannot be compared to global food production. Production conditions and production methods in the north differ greatly from countries further south. A global review does not do justice to Nordic food production methods and generalizes too much.
• p. 28 The southern part of Finland is suitable for growing cereals, vegetables and so on, but for example food grade wheat can only be cultivated in 1/3 of Finland, in the southern parts. Grass for animal feeds grows all over Finland.
• p. 58 New products replacing meat or dairy products in a meal are not yet available for the great public in terms of price and availability. The origin of the products might be unclear to the public.
• p. 60 Nuts and seeds, environmental impact of foods consumed: Expressed too generally. For example, there are big differences between Nordic seeds and nuts imported from outside Europe. There is no comprehensive information on the environmental effects of nuts, seeds, and almonds. For example, almond plantations in the United States use a lot of water resources.
• p. 133 Nuts and seeds: The site does not mention anything about afla toxin. There is a risk of afla toxin (and other mycotoxins) especially in nuts grown in warm and humid conditions.
• p. 137 Meat from dairy cows has lower GHG emissions than meat from sucker cows. This is correctly stated in the recommendations. However, the magnitude is relevant to notice as well. In Finland 80 % of the beef meat is from the dairy cows which lowers the impact to the environment significantly.
• p. 141 paragraph 4 It is important to notice that the carbon footprint of Nordic raw milk is 0,7–1,4 CO2 eq/kg while the global average is 2,5 CO2 eq/kg. The recommendations need to recognize the sustainability work Nordic dairy sector have already done.

On many Finnish dairy farms GHG footprint have been calculated and many dairy farmers have studied carbon farming. Therefore, already successful measures have been done on dairy farms in order to lower the GHG emissions. At present, several research projects are carried out. For example, in one of them cows' methane emissions may be proven to be cut by 30 %, by using Bovaer feed additive. Dairies, for example Valio, has very ambitious targets in terms of lowering the environmental impact. Valio’s ambitious climate program consists of concrete actions to cut milk’s carbon footprint to zero by 2035.

Soy is not used in cows' feeding in Finland. So, the statement that the usage of soy contributes to environmental stress outside the Nordic countries is not completely true. Silage made from grass forms the biggest part of the cows’ diet.

p. 142
Milk production is a remarkable agricultural sector in Nordic countries because of the climate conditions. Grass grows well also in colder conditions, even in Lapland, where the cultivation of grains and vegetables to food production is not possible. However, cows turn the grass to nutrient rich food. In the Nordic nutrition recommendations local conditions for agricultural production have to be taken into account. Dairy products are a major part of Nordic food culture because the climate conditions are favorable to dairy production. Unfortunately, local production conditions haven’t been taken fully into account in the proposed recommendations. Therefore, MTK suggests reconsidering the amount of milk and dairy products recommended per day. In Nordic countries dairy production can be done sustainably, for example comparing to areas where there is a shortage of water. A lot of work in the dairy chain has already been done and work is ambitiously on- going in order to reduce the environmental impact further.

p. 137:
“The largest proportions of overall environmental impacts from pig meat production tend to be a result of the cereals and soy in feed production and manure management (25).” Pig meat production in Finland uses domestic cereals and legumes, such as barley, protein isolates thereof, oats, wheat, and pea, as feed ingredients. The majority of farmed cereal varieties in Finland do not fulfill the technical and chemical safety quality suitable for food and the majority of feed cereal farming is conducted in areas where food quality cereals are not or cannot be farmed. 70 % of cereals farmed in Finland is fed to livestock. It is not mentioned in the text that pig meat production can utilize sides stream materials from food industry that would be waste if not incorporated back to the food chain via pig meat production. This should not be overlooked. The use of soy as feed component varies from 0 % to 3 % in Finland and is decreasing, since we are able to produce pea and cereal isolates as protein components for feed with less impact to land use and deforestation compared to soy. Therefore, the comments concerning the environmental impact of soy in pig meat production, if produced in Finland, is not valid – it applies to global pig meat production. Manure management in Finland is highly regulated and much effort is put to reduce the environmental burden of manure management – and it is also a fertilizer for plant production that can reduce the use of industrial fertilizers.

“Reducing the absolute amount of pork and chicken production could reduce the substantial environmental impacts of soybean production, including deforestation.” This statement does not take into account the fact that reducing production in Nordic countries will not impact to global soy production since it would increase the import of pig products from countries that do not put effort on reducing the use of soy as feed. Reducing the use of soy in Nordic pig and poultry meat production has been done already with good results. We suggest the following wording for this statement: “Reducing the absolute amount of imported pork and chicken could reduce the substantial impacts of soybean production, including deforestation.”

“Main data gaps. We lack studies on the health effects of different types of red meat. Little is known about the nutritional impact of how they are reared, e.g., fatty acid profile of meat from feedlot cows versus grassland herds. Data are still lacking on the health effects of substances formed when meat is processed.” It should also be mentioned that there is not adequate data on pig meat fatty acids composition from this decade from Nordic countries. The feed quality and feeding recipes (the use of rape seed in feed for example) have changed after pig meat fatty acid analyses have been performed. This applies to Finnish data especially. Finnish pig feed is different compared to global and central European production methods. After the data gaps of pig meat fatty acid composition and other nutrient composition is updated, it should be evaluated whether pig meat can be classified as white meat for both environmental and nutritional framework as the environmental data of pig meat production is more comparable with other monogastric species and foods thereof. Ruminants in Finland are fed with gras based feed and it has been shown to have an impact on the sensory quality of meat, and therefore it should be looked into if it also has an impact on the nutritional quality of ruminant meats. Red meat: the group should be divided into unprocessed red meat and processed red meat as the health effects are quite different. So should white meat.

• p. 138
“GHG emission from pigs is lower than ruminants, but demands for feed is high.” Compared to what? The feed conversion ratio (FCR) of pigs produced in Finland is very close to FCR of Finnish chicken production. This statement is lacking comparison. • p. 139 “Feed production (mostly cereals and soy) and manure management, has an environmental impact which cannot be neglected (25, 215).” We have new scientific LCA calculations on Finnish broiler production, which can be useful. Available at: https://doi.org/10.1016/j.jclepro.2023.137097

Heidi Siivonen

ruokamarkkina-asiantuntija, kuluttajatyö

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