KSLA’s comments on the open consultation of the Nordic Nutrition Recommendations 2023 (NNR2023) report

Summary

The basis for this review was to examine the proposals for future recommendations on desirable daily intake of individual nutrients and the consumption of different food groups, as well as the highest possible food self-sufficiency. The more specific national aspects will be addressed once the Swedish Nutrition Recommendations are presented at a later stage.

• The public consultation on the NNR2023 draft does not provide comparisons with current recommendations from other expert groups worldwide or explanations in detail as to why certain significant changes have been made compared to the previous edition of NNR 2012. This made it difficult for KSLA to assess the relevance and scientific basis of such changes.
• An overall principle in the draft of the NNR 2023 report is the need for a reduced consumption of meat, and in particular red meat. KSLA does not support the proposed new guidelines for red meat consumption. Instead, we suggest the application of the existing guidelines from the Swedish National Food Agency, i.e. an upper tolerable consumption of (350–)500 g of ready-to-eat red meat per week, which takes into account several health aspects integrated with environmental aspects as well as a high food self-sufficiency. The Academy would welcome a discussion about the distinction in health aspects between processed and unprocessed red meat as well as different cooking methods.
• Dairy products, sourced from sustainable dairy production, is an important primary and easily accessible source of calcium. However, viable dairy farming requires a market for bovine meat, and would be negatively impacted by a general reduction in red meat consumption. KSLA would welcome a discussion about differences in ecosystems services and potential benefits of circular production systems among different types of meat production.
• Connections between the climate and biodiversity crises and the necessity to halt and reverse biodiversity loss should also be taken into consideration in the NNR. KSLA strongly advise that these aspects (and conflicting interest) should be considered and discussed in detail.
• As has emerged from the Academy’s analyses, there are several potential areas of conflicting interests regarding a future agricultural policy versus a future nutrition policy. It is important that these problems are thoroughly investigated through a comprehensive system analysis in the near future.