It has been widely reported that Denmark has banned the sale of Marmite, a move that has shocked and outraged many Britons who love Marmite. Similarly, many Australians have been shocked and outraged by reports of a Danish ban on Vegemite. These reports are somewhat inaccurate. Companies that wish to market products that are fortified with extra vitamins, minerals and other substances are required to seek prior approval from the Danish Veterinary and Food Administration before the product can be placed on the Danish market and this has yet to happen in the case of Marmite (or Vegemite). These regulations have been in place in Denmark since 2004 but have not been applied to the case of these fortified food spreads until now. See: http://www.amblondon.um.dk/NR/exeres/8A56692E-1780-495E-8176-F0E366653F52,frameless.htm?NRMODE=Published
No doubt the makers of Marmite and Vegemite will apply for permission to market their products in Denmark. The broader concern here, though, is that the procedure that Denmark uses to decide whether or not to allow fortified food products to be marketed appears to be inherently flawed and has led to bad decisions in the past. In 2004 Denmark banned the cereal manufacturer Kelloggs from adding vitamins to their range of breakfast cereals and cereal bars on the grounds that overdoses of such vitamins and minerals could damage the kidneys and livers of children and pregnant women. While it is true that this could happen, it appears to be a very low risk. Fortified cereals have been available in America, Britain and a host of other countries since the 1930s and are consumed by millions of people and do not so far, appear to have caused clear cases of such damage. See: http://www.guardian.co.uk/world/2004/aug/12/foodanddrink
One concern here is that the Danes appear to have overestimated the extent of the risk of vitamin overdose by excessive consumption of fortified foods in the past. Another concern, though, is that they have failed to take account of the risks to people’s health of not having fortified foods available. There are many people in the world, including Denmark, who suffer from vitamin deficiencies that affect their health in a number of ways. By disallowing the sale of certain fortified foods the Danish authorities are exacerbating this health problem. It is unfortunate that the Danes have failed to take account of the health risks involved in prohibiting the marketing of fortified foods in their risk assessment, but not surprising. European health and safety regulation is dominated by precautionary approaches which encourage an excessive focus on certain classes of risks and a neglect of consideration of other risks. For more on this line of criticism of the ‘precautionary principle’ see Cass Sunstein’s Laws of Fear: Beyond the Precautionary Principle (Cambridge University Press, 2005).
Another concern is that the decision to ban fortified foods is excessively paternalistic. Banning the sale of fortified foods on health grounds takes decisions regarding the consumption of fortified foods out of the hands of consumers. A better approach, which respects the right of people to make their own decisions regarding their health, is to allow the sale of potentially dangerous foods, but include health warnings on them. Tobacco and Alcohol are far more dangerous for people’s health than Marmite and Vegemite but we do not ban these. Instead we seek to educate people about the dangers of drinking to excess and of the long term damage that smoking cigarettes can cause. The Danes do not ban the sale of tobacco or alcohol, and this leads to a final concern about their policy regarding fortified foods. It is flat out inconsistent with other Danish policies.
The Danish ban on Marmite is inherently flawed and should not be spread beyond Denmark.
Hi Steve,
Is it ever possible to apply the precautionary principle (in whatever form) consistently? My guess it's either paralysing or piecemeal. I've read Steve Gardiner's Core Precautionary Principle piece, which identifies a core principle and some "triggers" that might activate it (so it's application is "piecemeal" in the sense that you only apply it in some instances). Are there any attemtps to defend comprehensive applications of the principle (whatever it may actually be…)?
[Personally I think marmite and vegemite should face a tax: (1) to cover whatever risks fortification brings but mainly (2) because they're revolting.]
Hi Dave,
much worse than Marmite or Vegemite is the New Zealand variant Promite! I agree that the precautionary principle is paralyzing: see my article ‘Future Technologies, Dystopic Futures and the Precautionary Principle’, Ethics and Information Technology, 7, September 2005, pp. 121-126 where I argue exactly that. I'm also in print attacking Steve Gardiner's limited defense of the precautionary principle: see my ‘New Technologies, Common Sense and the Paradoxical Precautionary Principle’, in Evaluating New Technologies: Methodological Problems for the Ethical Assessment of Technological Developments, edited by Paul Sollie and Marcus Duwell, Dordrecht, Springer, 2009, pp. 159-173.
Thanks for the refs! My impression is that the PP has a whole heap more cred in Europe than it does in the Anglophone world. Also that it's popular with some academic communities (environmental studies, geography, that sort of thing) but not with philosophers or economists or the like. That's certainly the read I get from chatting to climate people about it. Is that roughly right?
PS – "Promite" – even the name brings shame to my country.
Hi Dave,
I can't speak for economists but yes the PP is not held in high regard amongst philosophers, although there are several that try to defend some or other stripped down variant of it. It seems most popular in the world on environmental law where a very tolerant attitude towards logical inconsistency prevails!
Hey Steve,
A better balanced view on the Marmite saga than what we've seen elsewhere. There is obviously political and health arguments for an against of fortified food. As far as I can see, one major concern is that some of those mentioned foods, also comes with a high content of sugar and other additives, which makes children and possibly pregnant women, more likely to eat more, rather than healthy. Hence why it in the long term is better to encourage intake of vitamins in a natural way.
However, as you correctly state, Denmark has not banned Marmite. Instead the manufacturer has not applied for approval, which I am guessing is related to the cost of the process versus how many actual jars of Marmite that anyone would be able to sell in Denmark – and that sounds to me like a loss making proposal 🙂
All the Best
Mads
Thanks for your comments Mads,
If the problem with fortified foods is, as you suggest, that many of them also contain added sugar then the solution is either to ban added sugar or require the disclosure of this fact to consumers, not to target all fortified foods. But I take it you have not tasted either Marmite or Vegemite. Both are extremly savoury tasting and not at all sweet and sugary.
No, I've tasted Marmite and very much like Twiglets.
My point was more about vitamins added into food that are being eaten in excess, rather than just the sugary example. But I also suspect that it is easier and more cost effective for the state to ask companies to apply for permission, rather than carry out individual checks on every single item in the chain.
It would be interesting to make direct comparisons on the health issues raised in the debate, between Denmark and England? Also maybe revisit the original data that led to the restrictions been put in place in the first instance.
The question that arises for me is why should it be breakfast cereals, or even more ridiculously Marmite, that should be the answer to the supposed problem of vitamin deficiency? What happened to eating fruits and vegetables?
And if we are talking about risk, just how great is the risk to Danes that are vitamin deficient (whatever this means) from no longer being able to readily consume Marmite? What do you mean vitamin deficient? In how many vitamins, of which kind and to what extent does a person have to deficient in order for us to be concerned about the fact that the don't have ready access to Corn Flakes or yeast extract spread?
The precautionary principle has many serious problems with it, but to invoke the health risk to vitamin deficient Danes of tighter regulation of fortified foods seems quite ridiculous to me.
Hi Dimitri,
it seems very odd to me that you uphold fruits and vegetables as a solution to vitamin deficiency in your first paragraph and then claim not to know what 'vitamin deficiency' is in the next paragraph. It's a commonly used phrase and if you are really in doubt as to its meaning you might try googling it.
There is evidence of vitamin B12 deficency in Denmark – e.g . http://mb.au.dk/en/single-news/artikel/danish-breakthrough-in-vitamin-research/ (despite the availabilty of a variety of fruits and vegetables in Denmark)and Marmite and Vegemite are both excellent source of vitamin B12. My point is that this fact should be considered in a risk assessment of the use of Marmite and Vegemite and that the precautionary principle, because of its exclusive focus on a narrow class of risks leads the Danish authorities to fail to consider it.
If you care to read my comment more closely, I never said I do not know what vitamin deficiency is. Rather, I wanted to draw attention to the fact that 'vitamin deficiency' is a very broad blanket term. There are very many ways in which persons can be vitamin deficient. Consequently, there are similarly many ways in which these deficiencies may be addressed and herein arises the question: How important is marmite in addressing the various vitamin deficiencies that do, no doubt, exist in Denmark? Your post implies that it is of quite some importance, but you have not even attempted to make a case for this claim.
Danes and many others suffer from B12 deficiency, as you claim. This is a statistical fact, and not open to argument. What is open to argument is whether Marmite or Corn Flakes are proper solutions to this problem. And with respect to that the question is wide open. Indeed, the very link you provide claims that "The only way to treat the disease is to inject vitamin B12 every three months" thus casting doubt on whether a vegetable spread or a breakfast cereal is the solution to the disease. I confess ignorance of the pathology, but I suspect that nutritional supplementation is in principle not the solution due to failure to uptake the molecules through digestion.
well I'm very pleased to read that, despite appearances, you do know what 'vitamin deficiency' means. I guess I am a bit mystified by your distinction between proper and improper solutions to the problem of vitamin deficiency. I don't know about the relative importance of various solutions to the problem of vitamin deficiency. My view is that, all things being equal, if marmite, vegemite, fruits, vegetables, fortified cereals and so on are solutions then all should be available. I take an anti-paternalistic line on this – the decision about which solution or solutions to apply should be up to the consumer.
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