Good Practice Principles for Regulating Large‑Scale Food Fortification

Principle 1: Evidence is used to identify micronutrient gaps and inform policy responses

 

Principle definition
The choice of a policy intervention to address micronutrient deficiency(ies) is informed by comprehensive evidence – both scientific and economic – to ensure that the choice is best-suited to the national context.
Sub-principles	Criteria
1.1. Scientific evidence is collected to help identify potential micronutrient deficiencies in the population.	Scientific evidence is collected and available on micronutrient deficiencies
1.2. Evidence is used to evaluate policy options and select appropriate instruments or intervention(s).	A range of different policy options – including the possibility of no action at all – is identified Potential impacts of policy options are thoroughly assessed using available evidence to drive the selection of appropriate intervention(s)
1.3. Evidence is used to consider and target fortification interventions.	Scientific evidence is used to determine which micronutrient(s) could be added to foods Scientific and economic evidence inform the selection of potential staple foods for LSFF
1.4. Stakeholder feedback is used early and systematically throughout the policy cycle.	Stakeholder engagement is undertaken throughout the development, implementation, and revision of national policies, regulations, and standards Efforts are made to ensure engagement is representative and meaningful

Good nutrition policy starts with evidence – and impact comes from how that evidence is used to inform decisions. Data on micronutrient deficiencies, diets, markets, and delivery systems – when available – only improves outcomes when it is systematically linked to concrete policy choices: which deficiencies to prioritise, whether fortification is the right tool, which foods to fortify, and under what regulatory approach. Principle 1 focuses on making that link explicit and structured, so that evidence does not sit in reports but actively informs policy design.

Policies can misfire when decisions do not follow structured, evidence-informed processes. Governments may mandate fortification of a food that target groups rarely consume, set nutrient levels without intake data and create safety risks, or choose regulatory approaches that exceed enforcement capacity, ultimately resulting in low compliance and weak coverage. The result is often the same: resources are invested and rules are introduced, yet improvements in nutrition outcomes do not follow. Asking the right questions from the outset of policy design is therefore critical, because it helps prevent problems from arising post-implementation after rules have been adopted and industry has invested in equipment, labelling, and supply chains – at which point, course-correcting becomes slower, more costly, and politically harder. Table 1.1 illustrates how difficulties that arise post-implementation in LSFF can be anticipated through practical questions and considerations set out in this chapter.

Table 1.1. How early questions can prevent LSFF problems

Problems that emerge in practice	Questions to consider early to help anticipate and avoid the problems
LSFF rules apply mainly to large industrial millers, while most staple foods are actually milled and sold by small local operators outside the mandate. Most households continue buying unfortified products so overall coverage and nutrition impact remains low despite the programme being formally in place and compliance being high among regulated millers.	What proportion of the target staple food is supplied by small and medium-sized enterprises (SMEs)? Is the market highly fragmented across many small producers – and if so, can they realistically be included and monitored under a fortification programme? Are additional supports needed to help accommodate SMEs or is a broad fortification mandate not feasible? See Box 1.6 for discussion on integrating SMEs in LSFF policy
LSFF is implemented and fortified foods are available on the market, but health outcomes do not improve because consumers distrust fortified products or are unaware of their benefits, leading to low uptake. Additionally, weak hygiene practices undermine the intended nutrition impact even where fortified foods are consumed.	Are education programmes needed to build awareness on the role of fortified foods in a healthy diet? Are supporting communication and engagement measures needed to explain fortification processes and safety? Are common diseases or infections (e.g., diarrhoeal disease, parasitic infections) reducing nutrient absorption, and do LSFF plans link with disease control measures? See 1.2 for discussion identifying and weighing multiple different policy options
A single staple food vehicle, such as rice, is chosen for a nationwide fortification program, but different states/areas within the country have different dietary habits – e.g. some regions primarily consume bread instead of rice. As a result, LSFF achieves desired health outcomes in certain regions but is ineffective in others.	Which fortifiable staple foods are most widely consumed by the target population and at-risk groups? Are there regional or demographic variations in consumption that affect coverage? Are multiple food vehicles needed to ensure sufficient coverage for LSFF? Do regional production and distribution systems support fortifying different foods in different areas? See 1.3 for discussion on the use of scientific and economic evidence to select staple food vehicles.

Source: Adapted from Measurement Framework.

Different types of evidence on nutrition and LSFF can support different stages of the policy cycle. This paragraph sets out illustrative examples, but the distinction is not always clear-cut in practice, and the same evidence may inform decisions at multiple stages. For problem identification, data on micronutrient deficiencies and dietary intake help determine whether intervention is needed, which population groups are most affected, and which food vehicles could reach them. To identify and assess policy options, evidence on food vehicle consumption, market structure, industry capacity and regulatory feasibility helps policymakers compare possible approaches and assess whether fortification can be implemented effectively and at scale. For post-implementation review (discussed in Principle 2), data on industry compliance, programme coverage, and the amount of fortificant actually delivered help show whether the programme is operating as intended, while biomarker data and broader health indicators help assess whether it is improving micronutrient status and contributing to population-level health outcomes. Some forms of evidence, such as stakeholder input, are relevant throughout the policy cycle: they can help identify practical problems, test the feasibility of proposed approaches, and provide insight into implementation challenges and unintended effects once a programme is in place.

Principle 1 examines how scientific evidence from a variety of sources – such as national surveys, dietary intake data, clinical indicators, and the burden of micronutrient deficiencies – can be collected to help identify micronutrient deficiencies (sub-principle 1.1.). It then discusses how both scientific and economic evidence, from food vehicle consumption to market structure to regulatory feasibility to public health impact, can be weighed to identify and select feasible policy interventions (sub-principle 1.2.) and how that evidence can be weighed to target LSFF specifically (sub-principle 1.3). It also details the importance of integrating feedback from a variety of stakeholders throughout the policy cycle to ensure chosen interventions are relevant and acceptable (sub‑principle 1.4).

1.1. Scientific evidence is collected to help identify potential micronutrient deficiencies in the population

Scientific evidence is required to support informed decision-making. Policy actions and interventions must address the micronutrient needs of a population by using evidence to identify deficiencies that are both widely prevalent and require attention to protect and promote population health. Employing a systematic approach to gathering, analysing, and applying the available evidence is vital to ensure policy actions are relevant, timely, and appropriate for the national or subnational context.

Availability of scientific evidence on micronutrient deficiencies

Micronutrient deficiencies (MND) are commonly identified via research using data on micronutrient indicators from national micronutrient, nutrition, and health surveys, including demographic data, clinical data, as well as dietary intake and household food purchasing information. While all the data sources listed may not be available in every country, data from the available sources may be viewed together or triangulated to support decision-making. The same types of surveys are also used after interventions have been implemented to monitor effectiveness.

Comprehensive geographical coverage of scientific evidence on micronutrient deficiencies is essential to gain a thorough understanding of their prevalence, gender impacts, regional patterns, and underlying causes. Data generation for micronutrient deficiencies in a country must include diverse demographic and socioeconomic groups, particularly those at high risk of malnutrition, including women of reproductive age, infants and young children, rural and remote communities, and very low-income populations. Ensuring all segments of the population are sufficiently represented in data collection activities allows for identifying the most impacted and vulnerable groups and designing actions and interventions accordingly. Excessive focus on national or broader averages can risk overlooking needs and deficiencies in specific groups or regions. For instance, dietary intakes of iron, calcium, vitamin D, folate, and iodine are lacking only in specific subgroups of European populations (EFSA Panel on Nutrition, Novel Foods and Food Allergens (NDA), 2022[28]).

Regular collection of scientific data on MND in a country is essential to ensure up-to-date, reliable information is available for evidence-based decision-making. In many countries, health and nutrition surveys are planned and conducted every five to seven years to measure the micronutrient status of the population and support evaluation and impact of policy options. However, in some settings, longer or shorter survey cycles may be applied based on the severity of identified problems or available resources. Because micronutrient data collection can be costly, prioritisation in the national agenda is critical. If no scientific data are routinely collected, steps must be taken to collect and analyse this data in the future.

Cross-sectoral stakeholder representatives, including representatives from the government, public health community, academia, and others, collaborate to gather and analyse data to prioritise the deficiencies to address. Insights, interpretation, and decision-making support from public health experts, nongovernmental organisations, and other researchers is critical especially when government capacity is limited.

Assigning a leading authority to collect or co-ordinate data collection is essential for ensuring accountability and strengthening co-ordination. This could be, for example, a team under the Ministry of Health or a research institute. The leading authority ensures that data is collected within a defined timeframe, using consistent methodology and data storage. When resources are limited, the leading authority can facilitate securing financial resources or collaborate with specialised organisations. Box 1.1 illustrates national data collection undertaken.

Box 1.1. National surveys in the Philippines and Viet Nam

Philippines

The Philippine Food Fortification Act No. 8976 mandates the National Nutrition Council to review food fortification every five years, aligning with the Food and Nutrition Research Institute’s National Nutrition Survey. This survey assesses micronutrient status (vitamin A, iron, iodine) and dietary intake, and its findings help to ensure national fortification policies are based upon recent evidence of national nutrition needs.

The 2018-2019 Expanded National Nutrition Survey also collected gender-disaggregated data, including micronutrient deficiencies for women of reproductive age (15-49 years), pregnant women, and lactating women, girls under five, school-aged girls, adolescent girls, and senior women.

Viet Nam

The National Nutrition Survey, led by the Ministry of Health of Viet Nam and conducted by the National Institute of Nutrition monitors MND across the population. Typically conducted every decade, the most recent survey took place in 2020. In addition to assessing MND indicators, the National Survey also monitors the prevalence of inadequate nutrient intakes.

2020 survey findings on MNDs have formed the National Nutrition Strategy for 2021-2030 targets – mid-term by 2025 and long-terms by 2030. The National Nutrition Strategy targets have been further incorporated in the 2021-2025 National Plan of Action for Nutrition.

Source: Philippines Congress, Food Fortification Act No. 8976, Philippines Food and Nutrition Research Institute (Department of Science and Technology) (2023), Philippine Nutrition Facts and Figures 2018-2019: Expanded National Nutrition Survey (ENNS), https://enutrition.fnri.dost.gov.ph/uploads/2018-2019%20enns%20facts%20and%20figures_july182023.pdf; Viet Nam: Government of Viet Nam (2022). Decision No. 02/QD‑TTg approving the National Nutrition Strategy for the 2021-2030 period. Tan, P. Y., et al. (2024). The Role of Complementary Feeding Practices in Addressing the Double Burden of Malnutrition among Children Aged 6–23 Months: Insight from the Vietnamese General Nutrition Survey 2020, https://www.mdpi.com/2072-6643/16/19/3240.

While national survey data is essential, the cost and resources associated with running these surveys can render them infrequent or insufficiently detailed in low-resource settings. In fact, costs are often reported as limiting whether and how many micronutrient biomarkers can be included in national surveys (Manger et al., 2022[29]). In the absence of national-level data to identify and confirm micronutrient deficiencies, other data sources may be triangulated as proxy measures to support evidence-informed decision-making. For example, without biochemical data, dietary intake data obtained via food-frequency questionnaires, 24-hour recall, or other validated measures may help identify dietary gaps and intake inadequacies that align with deficiencies. Health outcome data, including the prevalence of neural tube defects or goitre, may be used as evidence of population-level folate or iodine deficiencies. Subnational or regional micronutrient data (e.g., from neighbouring countries or the broader region) can be reviewed independently for relevance and significance at the national level. Novel approaches to estimating the prevalence of inadequate micronutrient intake may also be considered and are highlighted in the literature, including a modelling analysis using data from the Global Dietary Database (Passarelli et al., 2024[1]) and a machine learning model using country-level data on dietary diversity, socioeconomic status, and climate-related data (Voukelatou et al., 2026[30]). The Micronutrient Biomarker Initiative (MNBi) also represents an innovative approach to address micronutrient data gaps and provides a possible solution for countries with existing surveillance systems for HIV, tuberculosis, or other conditions. The core of the initiative focuses on three elements: utilising existing platforms to collect specimens, employing local laboratories for analysis, and integrating micronutrient, inflammation, and infectious disease data to inform policy. The initiative does not aim to replace national surveys, but rather to complement and strengthen national data systems (Sivalogan and Baingana, 2026[31]). Finally, together with these secondary data sources, expert consensus should be used to validate findings, identify the most likely deficiencies, and prioritise action in alignment with national nutrition plans.

1.2. Evidence is used to evaluate policy options and select appropriate instruments or intervention(s)

Effective policy design benefits from first assessing the problem using available data and evidence on MND and nutrition. Considering a range of possible responses (including maintaining status quo with any existing policies), and then systematically comparing their likely consequences, can help governments better understand whether public intervention is needed – and, if so, what form it might take. This approach helps align policy choices with available evidence, institutional capacity, and national priorities, and can reduce the risk of introducing rules that are difficult to implement or sustain.

In rulemaking generally, the process for systematically using evidence to think through the problem and potential policy options in order to identify the one best suited to a given context is referred to technically as Regulatory Impact Assessment (RIA). This is an iterative process guiding policymakers through problem definition; identifying multiple options for policy responses; assessing costs, benefits, and other potential impacts of the options; and planning for implementation, monitoring, and evaluation (OECD, 2012[12]). Illustrating what this can look like in practice, Box 1.2 sets out a new Regulatory Impact Analysis Framework to guide evidence-based policy decisions in Nigeria. While this book tailors and applies impact assessment principles to the specific context of addressing MND and LSFF, further information and guidance is set out in OECD materials such as the OECD Recommendation of the Council on Regulatory Policy and Governance (OECD, 2012[12]) and the Best Practice Principles on Regulatory Impact Assessment (OECD, 2020[32]).

Box 1.2. Regulatory Impact Analysis Framework in Nigeria

In 2025, Nigeria’s Regulatory Impact Analysis Framework was launched by the government’s Presidential Enabling Business Environment Council Secretariat, establishing a mandatory impact assessment process for all regulatory agencies – including those engaged in the governance of food and nutrition.

The Framework sets out a sequence of “critical questions” that policymakers must address using available evidence to justify new rules or changes in existing rules.

Critical questions

• What is the problem you are trying to solve?

• Why is Government action needed?

• What policy options are you considering? (starting out by seeking a non-regulatory solution)

• What is the likely net benefit of each option?

• Who did you consult and how did you incorporate their feedback?

• What is the best option from those you have considered?

• How will you implement and evaluate your chosen option?

• Which regulator should the regulations be under?

• How will you assess the social, environmental, and economic impact of the regulation?

• How will you mitigate any unintended consequences of the regulatory change?

• How will you collaborate with other government agencies to ensure coherent implementation?

Source: (Presidential Enabling Business Environment Council Secretariat, 2025[33]).

A range of different policy options – including the possibility of no action at all – is identified

The Principles focus on governing large-scale food fortification (LSFF) as an intervention to address MND, while recognising that micronutrient malnutrition can be prevented via multiple complementary interventions – including:

• nutrition education: promotes and enhances understanding of healthy dietary practices, such as the consumption of various food groups, and the importance of micronutrients, thereby encouraging better food choices among individuals and communities;

• water, sanitation, and hygiene: an integrated approach that emphasises the necessity of clean water and sanitation alongside hygiene education to prevent foodborne diseases and improve overall health, significantly contributing to nutritional outcomes. While this does not directly contribute to micronutrient intake, it helps to prevent malnutrition generally by reducing infections and improving nutrient absorption;

• supplementation: provision of specific micronutrients, often in pill or powder form, to individuals or populations to immediately address deficiencies and improve health outcomes. This is particularly common among vulnerable groups such as pregnant women;

• point-of-use fortification: addition of micronutrients or fortified blends to food at the household level, enabling increased flexibility but relying heavily on acceptance and proper usage among target populations; and,

• LSFF: involves the systematic addition of one or more essential nutrients to commonly consumed foods, and may be considered when required to meet the nutrient requirements in a population, maintain the nutritional value of a food, or prevent or correct a demonstrated deficiency in the population.

Recognising that the broader priority is to support access to healthy diets, LSFF is not necessarily the most suitable intervention in all cases. Countries may choose different approaches depending on the nutrient concerned and the population group affected; for instance, if a deficiency is confined to a specific population group, targeted measures may address the need more effectively. Alternative policy approaches or nutrition interventions may be more appropriate in a given country context depending on national needs, governance arrangements, institutional capacities, as well as existing health and nutrition strategies. Even if LSFF is selected following thorough assessment of various options, food fortification is not by itself a silver bullet to address MND. Rather, LSFF often functions in conjunction with complementary health and nutrition interventions. Accordingly, evidence is needed to understand the specific contribution of LSFF relative to other existing interventions – and how overlapping interventions specifically interact and contribute to health outcomes. Considering the full range of potential nutrition interventions and policy options allows for identifying the approach that is most likely to deliver desired outcomes within the given context of national public health and policy frameworks. Box 1.3 illustrates how policymakers in Colombia identified and considered various available nutrition interventions to address local MND before settling upon LSFF in conjunction with education measures.

Box 1.3. Identifying and assessing a range of policy options: Insights from Colombia

Context

Colombia identified in its National Nutrition Surveys (ENSIN) that the population has micronutrient deficiencies (including Iron, Zinc and Vitamins A, B12 and D), despite having legal and regulatory measures to overcome malnutrition. The deficiencies, in turn, lead to negative health impacts such as illnesses, mortality and disability, and negative socioeconomic impacts, low performance in education, higher healthcare costs, and impaired workforce productivity. The main status quo measure is mandatory LSFF of wheat flour (since 1996).

The Ministry of Health identified as the causes: 1) Insufficient contribution of the current array of fortified foods in Colombia, 2) Low diversity in the number of foods consumed by the population, 3) Publicity of low-nutritional value foods, 4) Food insecurity, 5) Insufficient production of basic foods, 6) Lack of access to clean water, 7) Infectious diseases which undermine micronutrient absorption.

Policy options

The Ministry sought to “contribute to the reduction of essential micronutrient deficiency in the Colombian population)”. To do so it performed a regulatory impact assessment, in which it identified a suite of potential policy options, including: status quo, promotion of agricultural sector development (e.g. implementation of new biofortification technologies), information campaigns, expanding food fortification, update of labelling regulations, measures to augment availability of drinking water, large‑scale anthelmintics, incorporation of food security and nutrition into income generation programmes, supplementation, and household fortification.

Initial options were reviewed in a preliminary assessment based on six criteria: 1) Constitutional viability 2) Novelty 3) Political viability 4) Health competency 5) Operational 6) Enforcement. Based on this, the Government finally identified three main options:

• Status quo

• Expand food fortification from only salt and wheat flour, to include maize flour and rice

• Information, Education and Communication (IEC)

Analysis and selection

After performing a cost-benefit analysis, which estimated the costs and savings of the healthcare system treating micronutrient deficiency related diseases that each option brought, together with the cost of implementing each option (for both government and private sector), the government concluded that despite the importance of all tools, expanding food fortification was the most cost-effective measure. This analysis was provided for public comments, including from relevant industries (maize flour mills and rice producers).

Currently, the government is working on adopting a new regulation which expands the food fortification to include mandatory fortification of maize flour and rice.

Source: (Ministry of Health and Social Protection, 2020[34]).

If LSFF is chosen as an appropriate intervention, policymakers can look at a range of policy instruments to foster fortification. Governments compare available tools such as voluntary guidelines that encourage fortification without legal obligations, industry self-regulation through codes of conduct, incentives or public procurement rules that reward fortified products, legislation that mandates fortification of specific foods at defined levels, and more. Looking across this spectrum, and at how instruments can be combined or phased, can help governments identify an approach that is both realistic for the local regulatory, market, and public health context, as well as positioned to achieve desired nutrition outcomes. OECD guidance also includes further discussion on available regulatory and non-regulatory approaches to help realise policy objectives (e.g. Reinforcing Regulatory Frameworks through Standards, Measurements and Assurance (OECD, 2025[35]); Alternatives to Traditional Regulation (OECD, 2009[36]); The spectrum of regulatory models and its application to the digital economy (King et al., 2026[37]), discussed in the context of digital regulation).

Mandatory and/or voluntary LSFF

A key point of discussion within LSFF policy is whether to make fortification mandatory or voluntary. Mandatory food fortification involves a legal requirement for producers to add specified micronutrients to defined foods, while voluntary fortification allows producers to fortify foods at their own initiative. Voluntary approaches can take different forms: in some cases, fortification standards are established and producers that choose to fortify must comply with them; in others, standards are absent altogether and businesses choose whether to fortify one or multiple foods and the level of fortificants to be added. Bangladesh illustrates how both approaches coexist within the same national framework: vitamin A fortification of edible oil is mandatory, while rice fortification in accordance with a published standard remains voluntary (Bangladesh Standards and Testing Institute, 2015[38]). In practice, these options are not absolute or mutually exclusive. Mandatory regimes can include voluntary elements, such as incentives or phased implementation. Voluntary regimes may also operate in ways that effectively resemble mandatory approaches – for example, if public procurement rules, market access conditions, or dominant buyers strongly encourage fortification, making participation necessary in practice. Over time, countries may also move between approaches, using voluntary fortification as a transitional step toward mandatory requirements, or adjusting mandatory regimes as capacities, markets, and public health needs evolve.

Table 1.2 highlights practical indicative criteria that can help policymakers weigh these options in light of their national context. This table presents indicative considerations, not strict conditions or a checklist that must be satisfied for either mandatory or voluntary LSFF. The factors listed will also not carry equal weight in every context and trade-offs are common; for example, strong public health need may point toward a mandate even where capacity constraints exist, in which case complementary measures – such as phased timelines, SME support, or simplified compliance mechanisms – become especially important. The conditions set out in these criteria can also change over time, particularly if there is strong backing by high-level decision-makers and a mandate driving change. The criteria are intended to help policymakers weigh which approach may be better suited to their national context at a given point in time – but as discussed above, these decisions are rarely binary in practice and may entail a combination of approaches alongside LSFF, or a decision that neither mandatory nor voluntary LSFF is appropriate as a policy intervention at the time. Further discussion on mandatory and voluntary fortification is also available in the Regulatory Framework for Food Fortification chapter of the updated Guidelines on Food Fortification with Micronutrients (WHO and FAO, forthcoming[39]).

Table 1.2. Indicative criteria for weighing mandatory and voluntary LSFF

Indicative criteria	Mandatory may be appropriate if:	Voluntary may be appropriate if:
Prevalence of MND	Deficiencies are widespread or clearly concentrated in specific population groups (e.g. by age, sex, region) – creating a clear public health rationale for universal, predictable coverage that mandates can deliver.	Reliable data on the scale, distribution or severity of deficiencies are limited or not yet available, or the identified scale of MND is limited/non-urgent. This may make it prudent to start with more flexible approaches while continuing to gather evidence, build market experience, and avoid disproportionate regulatory intervention.
Consumption patterns	Dietary habits of the target population are well understood, and there are widely consumed foods that are suitable vehicles for fortification, so a mandate can more reliably reach those at risk.	Information on dietary patterns is weak, outdated or highly variable across regions or groups – therefore, broadly mandating a specific vehicle risks low or misaligned coverage. Market-led uptake across different food vehicles may be complemented by approaches like small-scale fortification to allow flexibility or for data to be gathered.
Industry characteristics (Number of producers and method(s) of production	The industry engaged in LSFF value chain is sufficiently organised, with identifiable producers and/or centralised processing infrastructure capable of implementing requirements at scale – making it feasible to both implement and supervise a broad mandate, even where SMEs are prevalent upstream in production.	The industry engaged in the LSFF value chain is highly fragmented, dominated by small or informal/unknown producers that vary widely in terms of technical capacity and a lack of available centralised infrastructure – to an extent that renders an LSFF mandate infeasible to implement or enforce (or risks pushing businesses to noncompliance or informality). Market-led uptake may be complemented by alternative approaches, such as small-scale fortification, while building necessary industry capacity and/or infrastructure.
Industry and economic impacts (effects on cost and market structure)	Adjustment costs – both fixed (e.g. equipment, initial staff retraining, labelling) and variable (e.g. premix, inputs) – are manageable and unlikely to distort markets. Impacts on import/export for food and premixes are also well-understood and manageable. In this case, uniform rules can be feasibly applied without creating unfair advantages or forcing businesses out of the market.	Adjustment costs would fall unevenly on specific actors (such as SMEs or import-dependent food businesses) and distort the market; fortificants or foods are heavily import-dependent; or exports risk facing additional regulatory barriers in destination markets. A mandate in this case, without complementary mitigating measures, could actually shrink supply and reduce access to fortified foods by forcing businesses out of the market or into informality.
Demand drivers (commercial incentives to fortify)	Commercial incentives to fortify are weak, including a lack of consumer demand, or places firms at a competitive disadvantage. Businesses have a history of discontinuing voluntarily fortified products, citing challenges with net margins.	Strong market incentives already support fortification – such as consumer preference, public procurement rules, and trade requirements – and sustainably incentivise industry to engage in fortification without a mandate.
Cultural and stakeholder acceptance	There is a sufficient buy-in from consumers and industry to achieve a viable level of coverage without major resistance or avoidance behaviour in response to a mandate.	Consumers, industry, and officials strongly value market independence and prefer that fortification strategies reflect consumer choice rather than government mandates
Regulatory readiness	National fortification standards are in place or can be developed and implemented reliably. Government has or can feasibly develop the ability to monitor compliance, conduct inspections, and enforce requirements consistently.	Fortification standards do not yet exist or are being tested for national suitability or market-led uptake. Regulatory capacity is limited, or enforcement systems are still being developed or strengthened.

Source: (Hennessy, Walton and Flynn, 2013[40]), (Osendarp et al., 2018[41]); (Codex Alimentarius Commission, 1987[42]); (WHO and FAO, 2006[43]) (Brown et al., 2011[44]); (ASEAN Secretariat, 2024[45]); (Hystra, 2025[46]).

Potential impacts of policy options are thoroughly assessed using available evidence to drive the selection of appropriate interventions

Diverse evidence is needed to enable policymakers to assess the likely impacts of different policy intervention option – whether LSFF or otherwise – within their specific national context. Box 1.4, while not exhaustive, provides an illustrative list of data sources that policymakers can consult in order to collect evidence that is relevant for assessing the suitability and likely impacts of potential interventions. In several cases, the referenced data sources are discussed in further detail throughout this book (for instance, the use of Codex Alimentarius and WHO guidance under Principle 2, in the context of designing policies that align with international standards).

Box 1.4. Data sources for evaluating policy options

Global data sources

• Codex Alimentarius and WHO guidance: International standards and recommendations to benchmark nutrient levels and support alignment with global best practice.

• Food Systems Dashboard: Brings together country data on food systems from multiple sources and includes over 300 indicators that measure components, drivers, and outcomes of food systems at the country level (such as food security, dietary intake, and nutritional status).

• Global Fortification Data Exchange Database (GFDx): Developed in equal partnership by the Food Fortification Initiative, Global Alliance for Improved Nutrition, and Iodine Global Network, this database specifically tracks the implementation of food fortification worldwide, facilitating access to critical data for policymakers interested in LSFF.

• Global Health Observatory (GHO): Managed by the World Health Organization (WHO), the GHO offers data and analysis on global health, including statistics on micronutrient deficiencies relevant to food fortification considerations.

• Nutrition International cost of inaction tool: Rapidly generates estimates on the health, human capital and economic costs of inaction on stunting, low birthweight and anaemia (in women and children) for over 140+ countries. 

• Nutrition International MMS-cost benefit tool: Calculates incremental benefits and costs of transitioning from iron and folic acid supplementation to micronutrient supplementation based on country contexts and user-generated scenarios.

• WHO Global Database on the Implementation of Nutrition Action (GINA): Offers information on national nutrition policies, including those related to food fortification, providing policymakers with context for their decisions.

• World Bank Database on Food Prices for Nutrition: Provides indicators on healthy diet cost and affordability by country, which can help assess reach and feasibility of staple food options.

• World Bank Monthly Food Price Estimates by Product and Market: Provides data on staple and commodity food prices across countries and markets, supporting analysis of price trends, volatility, and affordability relevant to nutrition and fortification policy decisions.

• World Trade Organisation databases (e.g. Technical Barriers to Trade and Sanitary and Phytosanitary Measures notifications): Information on existing technical regulations and standards to assess trade compatibility and avoid unnecessary barriers.

National data sources

• Customs and trade authorities: Import and export data to understand reliance on imported foods and potential implications for trade and compliance.

• Ministries of Health and Nutrition surveillance systems: Data on micronutrient status, disease burden, and target populations to inform public health need and expected impact.

  • Health Management Information System: Many countries maintain a System that includes vital health data that can inform decisions on public health policies, including food fortification strategies.

• National statistical offices: Household surveys, demographic and health surveys, and nutrition statistics to assess dietary patterns, micronutrient deficiencies, and population coverage.

  • Food consumption and dietary intake surveys: Information on what foods are consumed, by whom, and in what quantities, helping identify suitable fortification vehicles.

• Regulatory Market Surveillance Databases: Market structure, production volumes, compliance tendencies, and cost data to understand impacts on businesses, including SMEs.

Source: (CODEX Alimentarius Commission, n.d.[47]), (Global Alliance for Improved Nutrition (GAIN) and Johns Hopkins University, n.d.[48]); (Food Fortification Initiative et al., n.d.[49]) ; (Nutrition International, n.d.[50]); (Nutrition International, n.d.[51]); (World Bank, n.d.[52]); (World Bank, n.d.[53]); (World Health Organization, n.d.[54]) (World Health Organization, n.d.[55]) (World Trade Organization, n.d.[56]).

Using the evidence gathered, policymakers can systematically assess the likely impacts of different policy options – including the likely impacts of inaction – before deciding how to act. The fundamental first‑level assessment is feasibility: is this policy option possible to implement? Is it viable in this country context? This can involve an assessment of available government resources as well as industry capacity to comply with associated requirements and costs. Assessment of feasibility and viability can then lead into a determination of effectiveness. Particularly for LSFF, which is often emphasised as a “cost-effective intervention to address malnutrition” (UNICEF, Gates Foundation and USAID, 2021[57]), robust assessment can help to determine whether and how cost‑effectiveness will hold in a given country and to identify the conditions under which cost-effectiveness can be achieved in practice. Impact assessment approaches encourage governments to look broadly at economic, social, health, administrative, and trade effects, rather than focusing on only one outcome. This involves combining quantitative analysis (such as estimating costs, price effects, health gains, or budget needs) with qualitative assessment (such as feasibility, equity, acceptability, and institutional capacity), especially where data are limited. Looking at impacts side-by-side also helps make trade-offs visible, for example, between public health gains and compliance costs for small businesses, or between speed of implementation and administrative burden; this enables policymakers to compare options transparently and choose approaches that best fit their national context and priorities.

Box 1.5 sets out an illustrative checklist of potentially relevant impacts to assess when considering LSFF and other nutrition policy interventions. The extent of assessment undertaken can be influenced by available data, and resources/capacity, or the magnitude of the regulatory proposal in question. Where feasible, quantitative analysis supports objective comparison (OECD guidance, for instance, sets out methodologies for quantifying compliance costs (OECD, 2014[58])). In line with OECD guidance, comprehensive assessment goes beyond a narrow focus on direct costs, such as buying fortification equipment, to also consider indirect costs – such as opportunity costs, effects on market structure and prices, or changes in trade patterns that result from the intervention. Wherever possible, identifying and assessing relevant benefits is critical to justify the rationale for policy intervention, including both direct benefits, such as improvements in micronutrient status and health, and indirect benefits, such as productivity gains and reduced pressure on healthcare systems. Assessment ideally also considers how costs and benefits are spread across different population and stakeholder groups, rather than just an aggregate assessment. In LSFF for instance, public health benefits may accrue across society, while the costs of equipment, premix, testing, and quality control appear on the balance sheets of individual companies. A qualitative and/or quantitative analysis of distributional effects can help identify whether small firms face disproportionate compliance costs or whether rural populations benefit less from improved health outcomes. The United Kingdom’s RIA on proposed regulations to fortify flour with folic acid, for instance, set out costs to businesses, costs to consumers, costs to government, indirect longer-term consequences, and risks; there was also specific consideration of impacts on small and micro businesses, societal impacts, equality and family test issues, and effects on competition (UK Department of Health and Social Care, 2019[59]).

Box 1.5. Checklist of potential impacts to consider

The list set out below is not comprehensive, nor will all impacts always be relevant or feasible to assess. This is intended to be an illustrative basis, upon which officials can expand or adjust based on specific intervention or context.

Impacts on Industry

• Substantive compliance costs

  • Upfront investment costs (equipment, dosing systems, lab testing, workforce training)

  • Ongoing operating costs (premix, quality control, reporting, audits)

  • Changes in production processes and timelines

• Impacts on SMEs versus large firms (ability to comply, risk of exit or consolidation)

• Administrative or reporting burden (including cumulative burdens, where requirements under across different policies/jurisdictions add up to the total burden experienced by a single entity)

Impacts on people

• Changes in micronutrient intake and nutrition outcomes (including prevalence and distribution of deficiencies, as well as risks of over- and under‑fortification)

• Health outcomes (reduced deficiencies, morbidity, mortality)

• Consumer impacts (impacts of labelling, claims, prices on consumer choice, cost, and demand)

• Access for vulnerable and remote populations

• Gender and equity

• Poverty

Impacts on government

• Administration and enforcement costs

  • Staffing and training needs

  • Costs of inspections, sampling, and testing

  • Data and IT system requirements

• Co-ordination needs across ministries and agencies, and subnational levels

• Monitoring and enforcement capacity (including accredited lab capacity to test micronutrients)

• Impacts on and interactions with other national policy goals or frameworks (including tax policies)

• Political context and support for implementation

Impacts on economy and broader impacts

• Effects on food prices and inflation

• Alignment with international and regional standards, trade, supply chain, and WTO/TBT/SPS compatibility

• Market structure and competition

• Labour market participation and workforce productivity

• Healthcare (including economic burden of illness)

• Environmental impacts of production changes (e.g. waste from reformulation)

Source: (OECD, 2020[32]; OECD, 2025[60]); (OECD, forthcoming[61]) (Hystra, 2025[46]); (Resnick, 2025[62]; 2024[63]); (Tarini et al., 2021[64]); (Theriault et al., 2024[65]).

Where resources and time are limited, this assessment does not need to be exhaustive to be useful. In practice, policymakers often cannot afford to wait for perfect, complete, and current data before making a decision – particularly when time and resources are limited. An impact assessment should therefore be a proportionate exercise that maximises the available evidence and helps to limit (but not eliminate) uncertainty. Countries can prioritise a small set of high-value questions first: expected nutrition and health impact, feasibility given industry and market structure, direct costs to industry, and government capacity to implement and enforce. Inevitably, this prioritisation will also be informed by what evidence is available and feasible to collect. Initial assessments can be complemented with targeted stakeholder consultation to provide a sufficient basis for early decisions, with deeper analysis added over time as data improves through monitoring and capacity builds.

Assessing affordability and access to fortified foods across different population groups helps ensure that an intervention delivers widespread benefits in practice. For example, fortification may improve nutrition outcomes in certain demographics but still have limited impact where low-income or rural households cannot afford the fortified product, do not regularly consume the selected food, or mainly buy from informal markets. Similar gaps can arise where small producers face high compliance costs and respond by raising prices, reducing production, going to the informal marketplace, or leaving the market altogether. One example of this concerns a pilot project on rice fortification in Madagascar, where fortified rice was well accepted and easy to distribute, but imported fortified kernels and related taxes increased the final price by around 20%. This made the product unaffordable for most consumers and financially unsustainable for many producers, despite its technical feasibility (Resnick, 2024[63]). Analysis of food prices, consumption patterns, distribution channels, SMEs and informal markets makes these risks visible and supports the identification of approaches that fit the national context. This can include phased implementation, complementary nutrition measures, centralised fortification (as described in Box 1.6). It can also include removing unnecessary regulatory barriers and aligning tariff policies to reduce costs, or leveraging public procurement, which are discussed further under Principle 6.

Actors involved in LSFF often specifically highlight the difficulty of adequately accounting for impacts on SMEs in food production and distribution. Research highlights the operational, regulatory, and cost challenges that smaller producers can face in participating in LSFF programmes (Kavle et al., 2026[66]) (Vosti et al., 2024[67]). Limited financial and technical resources can reduce their ability to comply with LSFF requirements, and the prevalence of informal SMEs can make it difficult for officials to monitor or enforce LSFF. Nevertheless, SMEs play a central role in global food systems – in low and middle-income countries, they provide up to 80% of food commodities and generate 40-70% of agri-food employment (Monroy-Gomez et al., 2022[68]) – and are therefore an essential area of assessment to ensure the effectiveness of food and nutrition policies.

The OECD’s SME test (Trnka, Reyes and Raes, 2022[69]) can be employed to help understand the various challenges faced by SMEs and how they may be impacted by different policy options. For instance, when implementing LSFF policies like salt iodisation, the OECD's SME Test can help identify potential burdens that might be placed on small-scale salt producers. This assessment could reveal whether the cost of complying with iodisation standards would disproportionately affect these businesses and limit their competitiveness in the market. This assessment can also help predict the effectiveness of certain policy choices, such as exemptions: for example, as observed in certain country cases, exempting SMEs may prevent fortified foods from reaching almost all households and critically limit the overall impact of LSFF as an intervention. By assessing these factors, policymakers can devise support mechanisms, such as financial incentives or technical assistance to smooth the transition of SMEs to mandatory fortification, or exemptions to scope out certain sets of entities. These strategies and application of the SME test to LSFF are discussed further in a forthcoming OECD paper on integrating SMEs in LSFF regulatory systems (OECD, Forthcoming[70]).

Box 1.6. Policy options for integrating or accommodating SMEs

Where SMEs account for a significant share of food production or distribution in a market, their capacity to participate in fortification can materially affect which policy options are viable. Considering SME characteristics early in the policy process helps identify approaches that can achieve broad coverage in practice, rather than relying on requirements that smaller operators may be unable to meet.

1. Alternative strategies can be employed alongside LSFF to integrate SMEs in food fortification, but should be used carefully to avoid distorting the market and pushing out SMEs altogether.

• Small-scale fortification: Contrasting LSFF, which typically covers only registered medium-large producers, small-scale fortification refers to fortification undertaken among small-scale, cottage or artisanal industries – primarily occurring in the informal sector but also encompassing registered SMEs.

• Centralised fortification: Fortification activities can be centralised through, for instance, centralised collection centres that serve as hubs where staple foods are fortified with micronutrients before they reach the market.

• Public procurement of food: By linking fortified staple foods to social programmes, government can drive stable demand and open space for SMEs to enter structured markets; participation in public procurement can encourage SMEs to formalise and grow.

2. Exempting SMEs from mandatory fortification requirements can be a regulatory response where capacity is low or supervision is impractical – but exemptions also reduce fortification coverage and can create unintended disincentives for firms to grow.

• SME exemptions can be narrowly defined by objective thresholds (e.g. production volume), time-limited, and targeted based on evidence of disproportionate costs or complexities in specific areas.

• Exemptions limit the coverage of fortification programmes and do not address root issues of capacity, informality, or fragmentation in the market; it is important, therefore, that they are paired with mitigating measures and appropriate consideration is given to their use as transitional measures rather than a long-term solution.

3. Mitigating measures in the delivery of LSFF can be employed to relieve some regulatory burden that SMEs disproportionately experience.

• Flexible or extended transition periods for SMEs

• Simplified administrative processes or reduced information requirements

• Simplified and risk-based market entry requirements and processes

• Simplified and risk-based enforcement, with lighter-touch or less frequent inspections

• Financial support for compliance through fee reductions or facilitated access to financing

• Capacity-building through training and guidance to support compliance.

Source: (OECD, Forthcoming[70]).

1.3. When LSFF is considered, evidence is used to target food fortification interventions

Scientific and economic evidence is essential for targeting LSFF interventions precisely – helping identify which nutrients to add and which foods to fortify so they actually reach the populations affected by deficiency. Bringing this analysis in early when considering policy options strengthens decisions about the feasibility and design of LSFF interventions and increases the likelihood that fortification – when implemented – delivers measurable, real-world nutrition impact. This section builds upon established international guidance to guide decisions on identifying micronutrients and food vehicles, including WHO and FAO Guidelines (WHO and FAO, 2006[43]), Codex general principles for the addition of essential nutrients to foods (Codex Alimentarius Commission, 1987[42]), and the World Health Assembly’s Resolution on Accelerating efforts for preventing micronutrient deficiencies and their consequences through food fortification (World Health Assembly, 2023[71]).

Scientific evidence is used to determine which micronutrient(s) could be added to foods

Where LSFF is the policy option that is being considered or pursued, the selection of a micronutrient to add through fortification follows directly from the identified deficiency problem – for example, iodine where iodine deficiency disorders are prevalent or iron where anaemia rates are high. Scientific evidence should be used to determine the type and quantity micronutrient compounds (fortificants) to be used in LSFF (WHO and FAO, 2006[43]). Priority micronutrients for fortification often include one or more of the following: iron, folic acid, other B-complex vitamins, vitamin A, or zinc. However, other micronutrients may be considered based on deficiencies identified in the population.

Fortificants are micronutrient compounds and chemical forms, and their selection is informed by scientific evidence. The stability, bioavailability, suitability for fortification, and other technical parameters of fortificants must be carefully evaluated to ensure adequate micronutrient delivery and utilisation (WHO and FAO, 2006[43]). Bioavailability is the measure of how well a particular nutrient can be absorbed from a food and used by the body. For example, some fortificants must be dissolved in water or a dilute acid to be useable, and interactions between the fortificant and the food or other nutrients in the food can impact bioavailability. Suitability for fortification encompasses overall stability of the compound once it is added to the food; the influence of the fortificant on the sensory aspects of a food, including taste, appearance, and palatability; and other factors. Stability of the fortified food is important to ensure the level of fortification aligns with what is delivered and consumed. Storage temperatures, shelf life, and packaging play a role in stability, since high or low temperatures, extended storage times, and light can cause some fortificants to have off-putting tastes or smells or become less potent. In addition, fortificants may influence the taste, smell, or appearance of foods; sometimes, their addition may make fortified foods unpalatable or unacceptable to the population. For example, iron can cause foods to appear greenish, grey, or brown in some situations, which may make people less likely to consume the fortified foods. Finally, cost of fortification, and thus the cost of fortified foods, must be accessible for the population.

Evidence is also used to establish maximum and minimum limits for nutrient addition to ensure safety and effectiveness. The incorporation of maximum and minimum limits within the content of a national standard is discussed under Principle 2.3.

Scientific and economic evidence inform the selection of potential staple foods for LSFF

Choosing the right food vehicle follows, in turn, from both the identified micronutrient deficiency and fortificant, as well as data on what affected groups eat. A food vehicle may be commonly consumed but not practical to fortify at scale if production is fragmented, informal, or difficult to monitor. Conversely, a centrally produced food may be easy to fortify but may not reach the most vulnerable groups, while an ideal vehicle is centrally produced, reaches the entire population, and is consumed in homogenous quantities or in higher quantities by lower-income consumers. Vehicle selection should therefore consider both consumption by target populations and the practical feasibility of fortification and regulatory monitoring.

Commonly consumed staple foods, including wheat, corn, rice, salt, oil, or others, may be considered as staple foods to be fortified. The foods to be fortified with vitamins or minerals are also commonly called food vehicles. In practice, certain nutrients and food vehicles naturally go hand in hand because of technical compatibility and established delivery pathways – for example, iodine with salt, iron and folic acid with wheat or maize flour, and vitamin A with edible oils or sugar. Scientific evidence on MND can also guide which food vehicles are prioritised by linking specific nutrient gaps in the population to specific foods that are widely and regularly consumed by the groups most affected (Codex Alimentarius Commission, 1987[42]) (World Health Assembly, 2023[71]). Together with economic data (including market structure and food industry dynamics; the influence of food processing and manufacturing factors on fortification feasibility; and consumer-related factors), this collectively informs the selection of appropriate food vehicles within the country context. WHO-FAO guidelines set out further considerations for the use of fortificants with specific food vehicles (WHO and FAO, 2006[43]).

Information and data on the food supply chain, industry characteristics, market structures, and the role of small and medium businesses in the food system can influence LSFF feasibility and must be considered (OECD, Forthcoming[70]). In addition, staple food consumption patterns, consumer familiarity with the food vehicle, local food preferences, and availability, accessibility, and affordability of staple foods, can be critical for food vehicle selection. Finally, the needs of vulnerable and hard-to-reach populations, including those living in poverty and others who are particularly susceptible to MND, may warrant specific and careful evaluation. In Costa Rica, for instance, the government adopted a national LSFF programme focusing on rice and wheat flour as staple foods. These staples were selected due to their widespread consumption among the population and their role in combating anaemia and micronutrient deficiencies. Box 1.7 sets out a further example from Guatemala.

Box 1.7. Use of national and scientific data to inform staple food selection

Guatemala’s Household Income Survey (referred to as ENCOVI) collects essential data on food purchases which are relevant for food fortification regulation. The survey records data such as food obtained in the last 15 days, the quantity, the source (homegrown, processed, traded, or purchased), as well as the gender, age and income of household members.

Since 2006, the data collected, together with standard information on food composition, has enabled the Government of Guatemala and researchers to estimate the nutritional calorie and micronutrient intake, analyse consumption patterns, and assess micronutrient inadequacy rates, making ENCOVI a valuable tool for food fortification regulatory design and impact evaluation. 

An example of how ENCOVI data can be used to inform national staple food selection is highlighted by analysis from Fiedler and Helleranta (2010), finding that: 1) food consumption data reveals that a larger segment of the population benefits from fortified wheat flour than previously estimated, meaning the impact of the wheat flour fortification programme is much greater than initially thought, and 2) fortifying semolina flour (used in pasta) could extend the benefits of wheat flour fortification to 60,000 additional unserved households and increase the consumption of fortified foods for 68% of the population, including the extreme poor.

Source: (Fiedler and Helleranta, 2010[72]); (Méndez and López, 2022[73]). (National Statistics Institute of Guatemala, 2015[74]).

1.4. Stakeholder feedback is used early and systematically throughout the policy cycle

The impact of LSFF programmes depends on the inclusion of perspectives from those who, themselves, are impacted by the intervention. Early and systematic stakeholder engagement ensures LSFF policies are well-informed, context-specific, and broadly supported. Furthermore, early engagement builds trust, surfaces potential challenges before they escalate, and allows for the incorporation of lived experiences and diverse sectoral expertise into policymaking. When carried out meaningfully, early and systematic engagement fosters transparency, enhances accountability, and increases the likelihood of sustained compliance and impact.

Stakeholder engagement is crucial throughout the development, implementation, and revision of national policies, regulations and standards

Effective stakeholder engagement begins early in the policy cycle, with diverse stakeholders being included in agenda-setting to help define the problem and inform the identification of different options for policy intervention. Ideally, this means engaging stakeholders before LSFF is chosen as an intervention, soliciting external perspectives on a range of possible interventions from the variety of actors implicated across the food system – including other parts of government, industry operators, academia, consumers, and vulnerable populations. Engaging these diverse groups throughout the regulatory cycle – starting from problem identification and policy design, through to implementation, evaluation, and revision – helps ensure that LSFF policies are technically sound, socially equitable, and practically feasible.

A clear and transparent consultation process, conducted in a systematic and structured way is crucial to allow for gathering diverse perspectives. For example, Food Standards Australia New Zealand (FSANZ) collaborates with stakeholders across governmental agencies, regulatory experts, public health experts, industry, academic researchers, and consumers. Beyond the legal obligation to engage stakeholders in the development of new standards, FSANZ also employs routine engagement to inform their work across topics including food safety, food policy, and monitoring, through formal and informal consultations, cooperative work, and advisory committees (Food Standards Australia New Zealand, 2018[75]).

Effective engagement can take many forms and be adapted to national context, demographics, capacity, and the stage of the policy cycle. Beyond one-way information sharing to inform people of LSFF and nutrition policy initiatives, engagement processes may include written consultation procedures, public meetings, technical workshops, advisory or expert groups, surveys, and online or digital platforms. Advances in technology mean governments are increasingly using digital tools to engage broad audiences on policymaking. In Latvia, for instance, the “Unified Portal for the Development and Agreement of Draft Legal Acts” is an online portal allowing any external stakeholder to find and comment on all regulatory proposals across ministries – including proposals related to food and nutrition (OECD, 2025[60]). Both broad consultations and more targeted engagement with specific groups – such as food producers, consumer organisations, health professionals, or vulnerable populations – can be valuable. Using a mix of approaches can help governments reach a wider range of voices, lower barriers to participation, and gather diverse perspectives that improve policy design (OECD, 2020[76]) (OECD, 2025[60]).

Standing feedback mechanisms that exist throughout policy implementation complement these approaches by creating ongoing channels for stakeholders and the public to share evidence on how LSFF policies are working in practice. This feedback, in turn, can feed into programme evaluation and updates (discussed under Principle 2.4). Tools such as helpdesks, complaint and query systems, digital reporting platforms, and regular multistakeholder-regulator fora like National Fortification Alliances (Box 1.8) allow governments to identify implementation challenges, unintended effects, and compliance issues in real time. Indonesia also established a National Food Fortification Coordination Forum under a 2024 decree to monitor the implementation of food fortification; the forum brings together the various ministries and agencies involved in fortification policy, as well as business associations, NGOs, and representatives of international organisations.

Box 1.8. Kenya’s National Fortification Alliance (NFA)

Kenya’s NFA provides a model for structured, multisectoral engagement to support the development and implementation of LSFF policy. Established by the government, the NFA brings together a range of public and private stakeholders including government ministries (Health, Agriculture, Industry, and Trade), regulatory agencies, food producers, civil society, academia, and development partners. The alliance provides a formal platform for co-ordinated dialogue, collective decision-making, and joint action on fortification efforts, enabling Kenya to align policy objectives with practical implementation realities and industry capabilities.

The NFA has played a central role in facilitating stakeholder consultations for the development of national fortification standards, raising awareness among industry actors, and supporting capacity building for regulatory compliance. By enabling regular communication between government regulators and the food industry, the alliance has also helped identify implementation challenges early and provided a mechanism for adaptive responses – such as technical support for small and medium enterprises to meet fortification requirements.

Kenya’s experience underscores the value of an institutionalised, inclusive, and transparent platform to build shared ownership, ensure accountability, and sustain progress in national LSFF efforts. This is consistent with research shared at the 2023 Micronutrient Forum on lessons from NFAs across nine countries, concluding that NFAs are useful for building trust in early stages of fortification efforts and continue to play a relevant co-ordination and management role for more mature efforts.

Source: (Nutrition International, 2020[77]); (Micronutrient Forum, 2023[78]).

Efforts are made to ensure engagement is representative and meaningful

Engaging vulnerable populations who are directly impacted by malnutrition – such as women, children/adolescents, people with disabilities, people living in poverty, people living in remote rural areas – to help design and implement LSFF policies is essential for maximising policy effectiveness and acceptance. This can require intentional effort by policymakers, as vulnerable groups tend to be underrepresented in traditional consultations. Box 1.9 sets out two select examples of community based and participatory engagement on LSFF targeting harder-to-reach populations.

Box 1.9. Targeted engagement for LSFF and nutrition

In Bangladesh, the success of salt iodisation as a policy was driven through community-based stakeholder engagement targeting rural communities. Local religious leaders, particularly Imams, were engaged by officials to conduct educational sessions on health benefits and help in building community support and acceptance for iodization initiatives. This strategic involvement was critical to consumer buy-in for policy implementation, which ultimately helped address iodine deficiency in the population.

In the Philippines, the development of a national Plan of Action for Nutrition was informed by a participatory and collaborative series of workshops and consultation activities spearheaded by the National Nutrition Council. Participants included “usual suspects” such as representatives from government, industry, development partners, civil society, and academia – as well as targeted consultation on a draft with children and adolescents, as key intended beneficiaries of the Plan.

Source: OECD Data Collection; (National Nutrition Council, 2017[79]).

Regardless of the specific consultation method employed, consultations can be structured to make it easy for people to participate. Providing clear and timely advance notice of consultations allows stakeholders to prepare and engage meaningfully. Using plain language, concise background materials, and clear questions helps participants understand the policy issue and the choices under consideration, regardless of technical expertise. Offering multiple channels for input – such as written submissions, workshops, and virtual meetings – can lower participation barriers, particularly in resource-constrained or geographically dispersed contexts. Finally, transparently communicating how input was considered and reflected in final decisions (for example, by publishing a summary of the input received or documenting responses to individual comments) helps build trust, encourages future engagement, and strengthens accountability throughout the policy cycle (OECD, 2012[12]; OECD, 2025[60]).

It is important for policymakers to also account for differences in stakeholders’ capacities and resources to engage. Beyond formal consultation processes, stakeholder groups may seek to contribute to and influence public decision-making through what is commonly referred to as “lobbying” or “interest representation”, namely activities, including communications with public officials, aimed at promoting their interests in public decision-making processes, including the preparation and implementation of laws and regulations and administrative decisions. Such lobbying and other influence activities are legitimate forms of political participation and can provide policymakers with valuable information, expertise and perspectives. However, in the absence of adequate safeguards, they can result in unequal access and advantages for certain groups, as well as opportunities for opaque or manipulative practices, leading to asymmetric or undue influence over public decision-making (OECD, 2021[80]; 2017[81]; 2026[82]). For example, smaller businesses or groups representing underrepresented or vulnerable populations may have fewer resources or less access to public decision-makers than more powerful or well-connected actors. Particularly in the context of LSFF, actors with direct commercial interests may have greater technical expertise and resources to engage consistently in policymaking than consumers or populations whose nutritional needs the intervention is intended to address. This ultimately increases risks of undue influence and policy capture. These risks can be particularly relevant where stakeholders have significant economic interests in the outcome of a regulatory decision, including major producers that dominate the LSFF value chain and businesses whose interests may diverge from public health objectives.

Promoting transparency and accountability in LSFF policymaking can help to mitigate these risks by making participation and influence visible, enabling policymakers to identify the interests represented and potential conflicts of interest or risks of undue influence and supporting meaningful opportunities for a broad and representative range of stakeholders to contribute. The OECD Recommendation of the Council on Transparency and Integrity in Lobbying and Influence calls on governments to promote transparency and integrity in lobbying and influence activities and to foster equitable stakeholder participation in public decision-making. To this end, it provides a framework for building coherent, comprehensive, effective and enforceable systems that strengthen transparency and integrity in public decision-making and mitigate risks of undue influence (OECD, 2010[83]).

Insufficient engagement with affected stakeholders can increase the risk of regulatory failure in LSFF, as has been observed in certain country contexts. When industry actors, consumers, or frontline implementers are not adequately consulted, regulations may prove impractical to implement, impose unforeseen costs, or fail to reflect market realities and consumption patterns. For example, a rule may require the use of a specific fortificant compound that is not reliably available on the local market, leading to supply bottlenecks and non-compliance. Local producers may also lack the capacity to adopt fortification practices within the implementation timeline set by the government. This can lead to low compliance, active resistance, or legal and political pressure that ultimately forces governments to delay, weaken, or withdraw fortification requirements altogether. Lack of engagement can also undermine public trust, fuel misinformation, and reduce consumer acceptance of fortified foods, limiting their uptake and impact. Specifically on consumer acceptance, it is important to note that the objective is not necessarily to encourage consumption of specific products, but rather to support informed consumer choice based on an understanding of the role of fortified foods within a healthy and balanced diet. Early, inclusive, and continuous engagement helps identify risks, build shared ownership, and increase the durability and effectiveness of LSFF policies.