Who Did the Union Govt's Food Policy Help? India’s Anaemic, or Vitamin Businesses and Big NGOs?

The third and final story in the series on the policy of rice fortification in India’s public-sector food programme, examines the lack of evidence and scientific consensus when India adopted compulsory food fortification.

If it does not really help those with anaemia and malnutrition, then who benefits? The story traces the lobbying for the policy by a handful of organisations, substantively funded by the Gates Foundation and its entities.

Meanwhile, the government cut budgets to social schemes providing freshly cooked and local food drastically. Instead of addressing the structural causes of hunger and food insecurity in inequalities in power, this “solution” of mandatory fortification, thus took India further away from improving food diversity and from climate resilience.

Read parts one and two.

Gumla (Jharkhand)/New Delhi: It was a breezy summer morning in Gumla, 100 km from Jharkhand’s state capital Ranchi. A private operator’s bus departed from the Gumla bus station for its destination in remote forest villages in the paat, highlands of the Chhotanagpur plateau in India’s east, home primarily to Adivasis. Dressed in clothes apt for a business meeting, a light blue shirt and dark trousers, with his thick mop of hair combed neatly, Rajesh Singh hopped on the bus.

A quack with the years of experience of selling dodgy medicines and cures in this Adivasi belt, Singh stood at the front of the crowded bus. He began advertising to a largely disinterested but wholly captive audience. “It is a new product! Called CMD – Concentrated Mineral Drops! Dawa dekhna ka paisa nahi lagta hai! I will not charge you for inspecting the medicines,” he began, as he fished out a packet of 12 multi-vitamins tablets. “In the USA, there is a place called Utah…From the Utah lake, famous for its nutrients, made from its special minerals, we bring you CMD! It will solve all your problems. From tooth decay, to balding, from addictions to sugar and liver ailments!”

A young woman farmer transporting a ceramic seat for her newly built toilet back in the village and young Adivasi men returning from working as temporary migrants in other states looked on as Singh continued the staccato pitch: “We bring it you from the USA! Just for Rs 600!” The slick salesman cited a sum nearly thrice the daily wage in these rural parts.

Finally, he walked to one of the Adivasi men, Sylvanus Ekka of Jokipokhar village on top of the plateau, who was returning after working on pineapple plantations in far-off coastal Kerala. “Bol beta, yehi mauqa hai. Take it son, it is your only chance!” he goaded Ekka till the quiet man carrying back the wages of last few months agreed to buy one packet of multi-vitamins pills from him. Despite his dodgy pseudo-scientific claims, Singh’s sale was successful and complete.

Far from Gumla, nearly 1,300 km away in New Delhi, organisations mainly funded and led by the Bill and Melinda Gates Foundation (BMGF) and international aid agencies have in a similar exaggerated vein pushed “food fortification”, adding factory-made vitamins and minerals to food staples, as a cheap solution to India’s government to fix its malnutrition and anaemia problem.

“Large scale food fortification” is the addition of industry-made nutrients to foods to improve their nutritional quality. Advocates of the policy argue that it is cost effective, and does not require changes in eating habits. Rice is a staple food of more than half of India’s population and is seen as suitable for adopting as a food vehicle for fortification.

The critics of this policy, which is in the process of being expanded and scaled up nationally, call it out as ineffective, wasteful and coercive. There is no evidence, they say, that it reduces anaemia. According to them, making this a mandatory policy – and scaling it up without adequate infrastructure and quality control (see part one of this series) – has concerning implications for the health and safety of vulnerable populations.

Despite high growth, India has some of the highest rates of anaemia and child undernutrition globally. Within South Asia, it fares worse than most countries, other than war-torn Afghanistan. The government has cited the severity of the health problem of anaemia and its stubborn persistence – 58% children were anaemic in 2015-’16 which worsened to 67% in 2019-’20 – to argue for food fortification. On one hand, it has now stated it will no longer collect data at district level on anaemia the same way, which had shown it getting worse. On the other, it has succumbed to a silver bullet “solution”.

Dr Arun Gupta, a paediatrician, a member of the former Prime Minister’s Council on India’s Nutrition Challenges, asked: “A central question is, how many of our children are eating well? Why is the other rich half of India doing fine?” He added: “Data show that below two years of age, only 10-11 percent infants get to eat diverse diets of at least four food groups. They are inadequately breastfed. In later life, these disadvantages becomes permanent.”

Dr Gupta said that so few children in the country get to eat well is an indictment of the state and of society.

“Instead of addressing the causes of poor diets, it has led India’s government to believe that they must come out with something to show. That has become an opportunity for the corporations, which have been advancing and propagating the concept of “hidden hunger” concept since a few years, to sell micronutrients,” said Dr Gupta.

How rice is being fortified is a dried powder “pre-mix” of vitamins and minerals – iron, vitamin B12, folic acid – is added to powdered rice. The paste is passed through pasta-extrusion equipment to manufacture new grains, with a slightly artificial appearance compared to natural rice.

The Union government has budgeted an estimated Rs 2,900 crore a year for implementing rice fortification all over India. Initially, in Phase 1 in 112 “aspirational” or poor districts, it provided Rs 722.7 crore; in phase 2 in 250 districts with high malnourishment the budget was Rs 1445.4 crore; and phase 3 in all India had a budget of Rs 2,810 crore. The three phases’ combined budget amounts to Rs 4,978.1 crore.

Public health experts and right to food activists have termed this a waste of public resources. Activists have accused India’s statutory food safety regulator, the Food Safety and Standards Authority of India (FSSAI), of failing to avoid conflicts of interest and of obfuscating information. They said by hosting a lobbying body – all of whose members were funded by the Gates Foundation – for over three years inside its offices, the FSSAI allowed nutraceutical and food corporations to influence decision-making, funding, implementation and evaluations to fortify food staples mandatorily in public schemes. This opened up a new market for multinational vitamin companies and the large food industry, while doing little to address the crises of chronic under-nourishment and anaemia among India’s poor.

The fortified food, supplied as a compulsory measure in grains supplied monthly as food rations and in children’s meals, is not accepted in rural communities. But they have little choice to forgo the food subsidies they survive on. It further diverts attention away from more sustainable approaches rooted in local, fresh and diversified food, they contended.

Opaque policy-lobbying

Prime Minister Narendra Modi first mentioned the food fortification policy in a radio programme on August 25, 2019. Most Indian residents first heard about it when the prime minister announced it in his Independence Day speech in August 2021. But the groundwork for the new scheme was laid much earlier, shows information obtained through interviews, and from Right to Information applications by The Wire, as well as public documents first published by The Reporters Collective.

On December 10, 2015, Bill Gates, the co-chair of the Bill and Melinda Gates Foundation, and Ratan Tata, the chair of the board of Tata Trusts co-authored an op-ed article in The Times of India. In it, they advocated focusing on 1,000 days between a woman’s pregnancy and her child’s second birthday and artificially adding micronutrients to food as among the top solutions for Indians suffering from malnutrition.

Both these approaches were earlier critiqued as inadequate by the UN former Special Rapporteur Olivier De Schutter in his report on the right to food on December 26, 2011. Schutter warned that inequitable access to food is the structural cause of malnutrition, which cannot be addressed by the focus on merely “1,000 days”, which still leaves out children, teenagers, older people and women who are not pregnant.

Instead, he emphasised the need for food systems inclusive of the poorest and small-scale farmers, that move away from mono-cropping staples such as only rice to diverse farming systems, protecting lactating women from economic pressures to support breastfeeding, and improving women’s direct access to productive resources. He noted fortified foods may be necessary only “where local production is insufficiently diversified and incapable of supplying full range of foods for adequate diets,” which is not the case in a vast agrarian country such as India.

Yet, both the Gates Foundation and Tata Trusts systematically advocated to fortify staple food with added micronutrients occupying an influential position in FSSAI, inside the Government India.

On November 21, 2016, the FSSAI set up a “Food Fortification Resource Center” (FFRC) in the presence of Bill Gates, the co-chair of BMGF, along with senior staff of the Tata Trusts at its New Delhi office. The FSSAI is a central body whose role is to regulate the manufacture, processing, distribution, sale and import of food in India.

The primary entity of the FFRC was the Tata Trusts, the philanthropic arm of the Indian corporate giant Tata Company, which has a range of businesses, including in food and nutraceuticals.

FSSAI officials told The Wire that the other key members of the FFRC included the US NGO PATH, the Canadian NGO Nutrition International (NI), and the UN’s World Food Programme (WFP).  

As explained in the following section, the Gates Foundation funds each of these entities to promote and lobby for large scale food fortification. Some of them have over the years partnered with the global food and fertiliser industry, as well as mining industry, in all of whose interests is the increase in business of manufacturing synthetic micro-nutrients. This has led to questions on the conflict of interest of these FFRC partner NGOs and their associated corporate entities that have a financial interest in fortification.

While a major component of the food fortification push is on rice with iron and vitamin B, the government has also made fortification compulsory in other food staples such as edible oil, milk and wheat, with other micronutrients including vitamin A and D.

India notified standards and norms for how several food staples may be voluntarily fortified in 2018. But regulators as well as industry bodies in rural areas such as Jharkhand stated in interviews that the demand for fortified food in markets remained slow to take off. Including it mandatorily in rice in India’s social safety net programmes, covering more than 813 million, led to one of biggest market expansions ever for such products. It has never been tried before in any other country mandatorily on such a large and diverse population having diverse food systems, and its impact at scale remains unknown.

The fortification scheme’s 2019 operational guidelines as well as a presentation titled “Need, Scientific Evidence and Alternatives” of the food ministry of June 21, 2021 supported fortification by repeating that rice is already fortified mandatorily in the countries Costa Rica, Nicaragua, Panama, Papua New Guinea and the Philippines. The combined population of these five countries is nearly 38 million or 3.8 crore. Thus, doing it in India’s public distribution system meant making it mandatory food for a population nearly 20 times greater, in one fell swoop.

Creating a market to fix malnutrition

Globally, the advocacy for chemically-fortifying food is led by an international consortium called the Global Alliance for Improved Nutrition (GAIN), which is registered as a Swiss NGO. The Gates Foundation had launched GAIN in 2002 with a US $ 50 million grant with an aim to address malnutrition by offering economic incentives to food corporations, such as Heinz, Kraft, and vitamin manufacturers such as Roche.

Reporting about this consortium’s launch, the Wall Street Journal with the headline ‘Gates Fights Malnutrition With Cheese, Ketchup and Other Fortified Food Items’ noted, in exchange for focusing on micronutrient deficiencies, GAIN offered the companies assistance in lobbying for favourable tariffs and tax rates and speedier regulatory review of new products in targeted countries. 

GAIN has worked with over 600 companies and civil society organisations in 40 countries. In 2014, 70% of GAIN’s budget for fortification focused on in India, Brazil, Indonesia and China. In India, GAIN’s interventions focus primarily on working with private sector to expand food fortification initiatives in wheat, edible oil, milk and salt. It runs a “GAIN Premix Facility” to make premix sale and procurement easier. Under this, it certifies producers of pre-mixes, provides guarantees for payments to premix suppliers, and offers extended credit terms to customers purchasing premix adding it to food. 

A 2014 critique of the consortium points out that GAIN’s Business Alliance for Food Fortification (which was superseded by the Scaling Up Nutrition – SUN – business network, launched in 2014, of which GAIN and the World Food Programme are co-hosts) included corporations such as Coca-Cola, Unilever, Cargill, BASF, many of which have been accused by civil society organisations of breaches of human rights and code violations that contribute to malnutrition. SUN and GAIN have been criticised for failing to “explicitly align their initiatives with human rights, including the right to food”.

Further, critics point out that financing of industrial food production by GAIN might create problems for local producers that lack the adequate technology. This is already being faced by India’s rural small rice mills, as reported in this series’ previous article. 

The critics of its philanthro-capitalism such as of the Gates Foundation express the concern that even as such foundations and consortium gain access and influence in many programme areas, little or no governing framework or oversight exists to show how they operate, or make them or their results accountable to public mandates. 

In India too, the Gates Foundation, through a mix of grant-making, personal networking and advocacy, placed itself at the center of the hub promoting fortification in India’s public sector food schemes, selling a quick-win solution, but offering little transparency or accountability. 

An “embedded” lobbyists’ hub

As stated earlier, an FFRC was set up inside the FFSAI in November 2016 in the presence of Bill Gates.

The Tata Trusts magazine, Horizons, in its edition of September 2019 with a cover titled “Nutrition Now”, stated that Tata Trusts is supporting the “10-member” FFRC, “which is embedded in FSSAI” and works with a spectrum of stakeholders “to propagate and promote fortification”. The article admits that “the most difficult bit is ushering in a bigger number of consumers into the fortification circle” but does not question why it is so. 

The magazine interviewed Shawn Baker of the Gates Foundation. Baker, who was the first director of nutrition at Gates Foundation, inaugural chief nutritionist at USAID and earlier worked with Gates Global Fund SUN, told the magazine that as Tata is a trusted name, “collaborating with Tata Trusts is one of our make or break partnerships” on nutrition in India. In the same interview, Baker mentions that in West Africa, large scale food fortification is going on since 2000 in 15 countries in salt, cereals, flour and cooking oil, though the “absolute number of stunted children are projected to increase” after “rapid demographic growth”.

Along with Tata Trusts, the FFRC included a number of Gates-funded international NGOs, such as PATH. It had no other local civil society organisations, who did not have links to food corporations.

PATH is a “product development organisation” initiated by Ford Foundation in 1977, which is heavily funded by the Bill and Melinda Gates Foundation. Both share longstanding institutional ties. In 1998, before the official establishment of the Gates Foundation, the Gates created the Bill & Melinda Gates Children’s Vaccine Programme with a donation of $100 million and this was administered by PATH’s secretariat in Seattle. As per its 2022 financial report, 43% of its funding was from one private foundation, and 32% from United States government agencies. PATH’s proprietary technology “Ultra Rice” is being used in the fortified rice being given in India. 

Nutrition International (incorporated as the Micronutrient Initiative in 2001) is a Canadian NGO that works to eliminate vitamin and mineral deficiencies in poor countries. In a detailed report, Alliance for Sustainable and Holistic Agriculture(ASHA) activists pointed out that Nutrition International It was a founding donor of GAIN. It has some private partners which have changed over the years. Many of these are manufacturers of micronutrients that they export to the countries such as India, Bangladesh and Pakistan, food and chemicals companies such as Mott MacDonald, Royal DSM, BASF, and as well as Canada’s largest diversified mining company, Teck Resources Limited, which manufactures zinc.

As stated earlier, the Gates Foundation funded each of these entities to promote and lobby for large scale food fortification in India. For instance, BMGF gave the Jamshetji Tata Trust $1 million for “nutrition advocacy”, and as its “India intermediary for smallholder farmer investment” (2015-’11), and Sir Dorabji Tata Trusts $3 million for “Food Fortification MIYCN(maternal and child nutrition) Joint Programming Platform” in 2016. It gave PATH a grant of $4.85 million to “scale up rice fortification in India”. In 2020, it gave Nutrition International $1.5 million to scale up large scale food fortification using rice, oil, double fortified salt through the social safety net programmes. Recently, in October 2023, it gave it $2 million to promote double fortified salt in India.

As for the fourth member of the FFRC, the World Food Programme (WFP), the head of WFP is appointed by the US government and it receives most of its current funding from US government. It lists the Gates Foundation as the first among its donors among foundations from across the world, and the corporation DSM as a partner on fortification. This feature of earmarked funds from private donors is criticised as contributing to institutional weakening of the United Nations and its specialised agencies, while also undermining implementation of integrated development strategies at national level.

These agencies were assigned as partners of state governments to implement the policy in states. For example, PATH was made a development partner by FFRC for Jharkhand and several North Eastern states, Nutrition International was appointed for Madhya Pradesh.

The FSSAI denied The Wire’s RTI requests sharing any contract agreements, or Memorandum of Understanding (MoUs) with the terms and conditions signed with these “development partners”, including the Tata Trusts. On their part, none of these organisations responded to email requests for commenting on, or sharing the terms of agreement for the work done as part of the FFRC in the government.

These organisations do not make a secret of their funds and lobbying to push for this policy. Some of them took credit for it on social media and in public statements. But in response to emailed questionnaires, they took no accountability or questions on its impact when the infrastructure of quality control, including laboratory infrastructure to test for micronutrients, were absent in India. They also did not respond to question on the risks of feeding iron-fortified rice as a mandatory measure when there is a health advisory against giving this to thousands living with thalassemia, sickle cell anaemia, or malaria, TB to whom increased iron intake can cause harm.

From 2017 onwards, central government meetings to decide on India’s food fortification policy between various ministries, the FSSAI and the NITI Aayog, India’s planning body, RTI documents show, were attended by senior staff of Tata Trusts, GAIN, and PATH. 

A revolving door existed between these organisations. For example, RTI documents show, PATH’s Project Lead of Nutrition, Rohini Saran, attended government meetings on fortification hired as a deputy lead of the FFRC inside the FSSAI. India’s central food safety regulator, the FSSAI, during a large this period was led by the government official Pawan Agarwal, who was the FSSAI chairperson from December 2015 till February 2020. A year after his retirement, Agarwal started working for PATH in 2022 to work as a consultant on food fortification, shows Agarwal’s LinkedIn profile.

“I advised PATH on rice fortification,” said Agarwal, in an interview at his newly-founded NGO the Food Future Foundation’s office in central Delhi. “But I am no longer working PATH, though my social media still mentions it as ongoing work,” he told The Wire.

On being asked about the agreements or MOUs signed by the FSSAI to host a hub to work with these development partners funded by the Gates Foundation, Agarwal clarified that there were no written agreements, or concrete terms and conditions. “We had an informal arrangement to work together,” he said.  “At the time, our focus was that when the decision (to fortify food) has been taken then we should do it right. That is why the hub FFRC was set up. Later, in my tenure, I tried to take up digitisation of the whole (fortification) system, audits for ensuring quality.”

Activists warn that though the government and these partners formally states it is just one approach “corporate-led fortification is on its way to becoming the main policy thrust”. Currently, holistic balanced natural diets, produced, processed by communities themselves, do not get the same support. 

The criticism is supported by comparing the budgets for fortification and millets. The union government is heavily advertising that growing millets will allow Indians to access better nutrition than rice and build climate resilience in India’s farms. But for five years, from 2018 till 2023, it gave a budget for “nutri-cereals” mission, on millets of only Rs 1031.4 crore. The budget provided for supplying chemically fortifying rice in one year is nearly three times, at Rs 2,900 crore. “Its lack of serious attention to millets or local foods is also evident if one compares the mission for oil palm budget, an agricultural commodity with little nutritional use, which was even larger at Rs 11,000 crore for 3-4 years,” pointed out a senior official of Odisha’s Millet Mission, who requested to not be named.

Questions were also raised early by India’s largest food product marketing organisation. The apex organisation of the dairy cooperatives, Gujarat Cooperative Milk Federation Limited’s then managing director RS Sodhi on October 3, 2019 wrote a letter to NITI Aayog expressing Amul’s “reservations against jumping on the bandwagon of mass synthetic vitamin fortification” of food staples. He instead advocated for only targeted fortification administered to only the persons who really needed it.

Agarwal added that though he found value in fortification of milk and edible oil, he had found rice fortification to be “more complex”, and difficult to ensure as being effective. “I now see human nutrition is far more complex, than a cookie-cutter solution such as this would be able to solve for.”

 Lack of scientific consensus

India’s notified target concentrations for fortification of different nutrients in several food staples in 2018. This was based on the recommendations of the FSSAI’s scientific panels. At the time, the choice to fortify or not was voluntary. But in 2020, it was made mandatory for some micronutrients. Supplying fortified rice mandatorily in India’s public-sector food programmes, which the poor rely on, was already on the anvil.

In 2021, soon after the prime minister announced the policy, it was clear that there was a lack of scientific consensus whether mandatory fortification works effectively, or would not lead to side effects. But the FSSAI’s own scientific experts cautioned against it. They said it should not be perceived as a panacea, and there was potential for excess intake, such that “the cure then becomes the malady.”

Under Section 13 of the Food Safety and Standards Act, 2006, the FSSAI hosts 21 “Scientific Panels”. These panels develop standards, and provide scientific opinions to the food authority. “SP-18” is the scientific panel on Nutrition and Fortification. At least two former members of “SP-18” were publicly critical of the approach of mandatory fortification of food as a solution to anaemia. Dr Anura Kurpad was a member of the Scientific Committee of the FSSAI till 2022. Dr HPS Sachdev was at the time of writing the Chairperson, FSSAI Expert Committee 1 for “Approval of Non-specified Food and Food Ingredients”. “The answer does not lie in the techno-utopia of food reductionism, seductive as it is,” they stated in an op-ed titled “A Flawed Recipe” in The Indian Express: “..The benefits derived from the nutrients in whole foods are greater than the sum of their parts.” Further, they warned, “meals in pill form” have been ranked by the Time magazine as “third in the top 10 failed futuristic predictions.” 

In a series of articles in the press and journal articles, Dr Kurpad and Dr Sachdev questioned the rationale of the proposal of feeding iron-fortified rice compulsorily as a way to reduce anaemia when the health ministry’s recent Comprehensive National Nutrition Survey(CNNS) showed that iron deficiency causes less than half of all anaemia cases in India (sub-clinical infections being among other reasons). They argued that India’s nutrition policy could not be based on the assumption that the causes of anaemia were same in all its diverse regions.

They enumerated serious concerns arising as India already has an iron supplementation program through use of iron tablets, and iron is also added to salt and flour given in public schemes. Both physicians flagged that fortifying rice too with iron would lead to over-layering, it could cause harm. Instead, they argued, the government ought to focus on supporting a diverse diet such as shown empirically by scientific trials in Koraput and Wardha to support adequate intake of fresh food.

At his office in Sitaram Bhartia hospital in Delhi, Dr HPS Sachdev, a paediatrician, stated that the decision to mandatorily fortify staples was not recommended by the FSSAI’s panel on fortification:

“I found about it (mandatory fortification of rice in the PDS) after the prime minister’s speech on August 15, 2021” said Dr Sachdev. He said the panel had been asked to helped set the standards for voluntary fortification, not mandatory. “The (FSSAI) panel’s work was limited to create standards to prevent harm from fortification, that is what should be the content, the standards, additives, in what concentration. This decision (to fortify the poor’s rations compulsorily) did not come from the scientific panel.”

Responding to a question about these scientists’ published concerns, Inoshi Sharma, a bureaucrat then executive director of FFRC, told this reporter, in March 2023 on the sidelines of a government summit: “The scientists are ex-members, and are free to say anything,” she said.

RTI documents show that in initial meetings on planning implementation of the scheme, on January 16, 2019, the Director (FFRC) described the role of FSSAI to include setting standards, creating regulations, use of only “plant sources for Vitamin D” (thus, ensuring vegetarianism), and “creating demand in open market for, and linking government safety net programs to fortified supplies.” the FFRC Director made recommendations on the central government’s fortified rice scheme that, “There should not be an end date attached to the scheme”. In January 2021, a memo of expenditure of the finance committee of the ministry of food and civil supplies too referred to it as “proposed to be an ongoing perpetually all over the country” scheme.

This is precisely one of the concerns the UN Food rapporteur Schutter outlined in embarking on such schemes. Schutter categorically recommended that such schemes must have “an end date”, to avoid creating corporate dependencies:  “Solutions that rely on imported technologies and products may create long term dependencies for the communities,” he warned. Giving the example of GAIN, which partners with companies to reach “the bottom of the pyramid,” or potential customers who are “too poor to constitute a solvent market in the short term”, he stated that any such intervention “should include a clear exit strategy to empower communities to feed themselves.” In contrast, Indian policy makers allowed lobbying in FFRC against having such an end date of the scheme.

Identifying an end date for mandatory fortification requires benchmarks and systematic evaluation. A letter by Alok Kumar Adviser (Nutrition) at NITI Aayog dated February 14, 2019 had stated the goal of fortification was “reducing stunting by 2% per year, under-nutrition by 2% per year, anaemia by 3% per year, and low birth weight by 2% per year”. On paper the scheme’s aim is to end anaemia. But in the districts where the schemes is implemented, no baseline evaluation – an initial assessment to measure the later changes against – was done. And as stated earlier, the government has this year discontinued the previous surveying of anaemia at the level of districts itself. 

While the scheme’s plan document recommended concurrent evaluation, setting up of central and state monitoring units, in a RTI reply, the food ministry stated that a central unit had been set up. It stated that the ministry did not have information on if states where the scheme is implemented among communities, have set up the monitoring units. Ministry officials did not respond to a question about an end date of the fortification scheme. Meanwhile, it is set to be scaled up universally by March 2024.

While the government’s policy to compulsorily fortify food has no clear end date, and it is continuing and even expanding, the lobbying hub FFRC, that till recently took credit for it, has been scrubbed off the Internet.

The activist groups ASHA and Right to Food Campaign published a report this February highlighting the potential conflicts of interest in the operating of FFRC within the FSSAI. Since then, the social media handles showing the presence of these organisations in government meetings and policy setting have been deleted. This reporter accessed the FSSAI fortification website at the start of the year in February when it mentioned FFRC and its team. On searching for it after April, the FFRC page was no longer accessible.

Inoshi Sharma, the former director of FFRC, told this reporter that the agreement between FSSAI and Tata Trusts was for three years. As per news reports, FFRC was launched in 2016, though as per Sharma it had been closed down after five years. 

“We had a three year agreement with Tata Trusts. FFRC closed down in August 2021,” Inoshi Sharma, told The Wire in March on the sidelines of a government summit in March while she was listed as executive director of FFRC on the FSSAI website. 

As the FSSAI did not respond to further questions on details of its terms of engagement with FFRC partners, when reporter visited the FSSAI building in August and September 2023 with follow up questions, the FSSAI staff stated that “FFRC no longer exists, and only the standards division works on fortification now.”

Its social media pages which were active till earlier this year were deleted this year, after public criticism around its opaqueness by ASHA activists.

“Largest market in anaemia”

While the outcomes on nutrition are not clear yet, the profits for large industry associated with fortification have grown.

One of the first companies to manufacture fortified rice kernels in India is JVS Foods Private Limited, which runs its factories in Jaipur, Rajasthan. In India, JVS Foods is one of the first facilities and the only facility manufacturing fortified rice kernels that is certified by GAIN, the Gates Foundation founded body promoting food industry-led solutions to hunger. Its related firm Wella Nutrologicals – both factories in Sitapura are a few meters apart – is certified by GAIN in dry premix. JVS supplied fortified kernels to Jharkhand, one of India’s poorest states with highest rates of anaemia and malnutrition, at the time of the pilot in the state for the scheme. 

Senior managers at JVS Foods told The Wire how their market and profits had grown manifold. Abhishek Jain, a senior production manager, and head of marketing, JVS Foods said they started production about seven years ago making barely 300 kilograms of fortified rice kernels a year, and now produced 200,000 kilo(200 tonnes) a day in the peak demand which lasted eight months a year, a massive increase.  

“Our first batch was bought by the NGO Akshaypatra,” Jain said, at his factory in Jaipur. “Initially it was mostly only private or NGO buyers. Then, the government came in. Now, primarily the government procures this. In this current financial year, we sold 3,000 tonnes rice kernels to Haryana government alone.” As FRK markets grow so does the market for pre-mixes. JVS told The Wire IT makes FRK and it imports vitamins premix via the Dutch firm, the world’s largest vitamin maker, Royal DSM’s unit in India, which in turn imported it from DSM Singapore. 

Jain further stated that PATH, the American NGO funded by the Gates Foundation, persuaded them to start supplying fortificants as a substantive business domestically and abroad opportunity, and which also led it to start pre-mix imports. “Among the first people to come to us was PATH,” recounted Jain. “About seven years back, they came and told us about the making of Fortified Rice Kernels. They told us that this is business of the future, and asked us: will you take part in this business?”

He added: “Ruchika(Chugh Sachdeva) (who is currently the BMGF nutrition lead in its India country office), who at that time worked in PATH, led this work with us. Their staff visited us, and we said alright, what be our costs? They told us that this market was expanding. In Vietnam, fortification was being mandatory in wheat flour, in Oceanic countries 100% fortification was becoming mandatory.”

“PATH told us that the future of this market lies in India, because there is such widespread anaemia in India. In fact, 90 percent of the world’s anaemia is in India,” Jain said.

He added that after they agreed, they accompanied PATH staff to China to select and purchase machines, equipment in 2016-17. “We went with PATH to China, and we spent around eight days there. PATH helped us meet 8-9 manufacturers there who make the equipment. Then we bought the first machine…It was PATH that did everything with us.”

PATH did not respond to an emailed question on the claims by JVS Foods staff. Ruchika Chugh Sachdeva, the BMGF’s nutrition lead in its India, declined an interview when this reporter reached out to her on her phone.

Nourishing profits

This lobbying on food fortification has parallels with what is happening in food and farming sectors of other poor and developing nations. One of the biggest corporations in this sector is the Netherlands’ Royal DSM, which was a chemical company for most of its history. It bought the vitamin division of Swiss healthcare conglomerate Roche in 2003, and is now the world’s largest maker of vitamins. In 2007, it became a partner of the World Food Programme, supplying the WFP with micronutrient powder. It has made nutrition its central business, especially in poor countries. For instance, in Rwanda, it sources soy from small farmers and gives it to Rwandan government processed as a micronutrient fortified porridge. It refers to the facility as the largest such nutrition factory sites in East Africa. In India, it exports vitamin pre-mix to firms such as JVS, and runs fortified rice kernel blending and processing facilities.

Food industry such as DSM, other agro-chemicals and pharmaceutical companies view “USD 2.3 trillion business opportunity” in implementation of Sustainable Development Goals related to ending hunger by 2030. Large aid agencies support this. For example, ahead of the Glasgow climate summit in 2021, the US government released a new strategy framing nutrition as a technical problem for agro-processors to solve. It stated it will invest USD 38 million in five years to expand “large scale food fortification” partnering with the Gates Foundation, GAIN, UNICEF. 

This business model approach to hunger assumes malnutrition is a simple problem with a technical fix. By not taking farmers’ role in ecology of food production seriously, and not addressing structural causes such as global trade, financial agreements that often restrict a country from supporting local smallholder farmers, such corporations and large aid agencies reduce the complexities of nutrition and dietary health to a process of adding in vitamins, a problem to earn profit off while solving.

“In the last 20 years, the dialogue has moved from how to enable access to good and healthy diets into silos, such as lack of micronutrients,” said Dr Arun Gupta, who convenes the network Nutrition Advocacy in Public Interest (NAPi). “I do not blame the corporations for their push. Eg. if they are making vitamin A or iron, they will want to sell those products. But when they start influencing government policy and lobbying for the use of these, then we ought to ask what is happening, in whose interests?” Gupta recounted that he along with other members of NAPi had staged a public protest in central Delhi when GAIN,  which co-chairs its SUN business network promoting industrial processed food along with DSM the vitamin-maker, first started lobbying with members of India’s parliament in 2008. “We held placards saying, “’GAIN is a pain!’ ‘GAIN go back!’” he recounted. “At that time, we succeeded in convincing a few MPs, senior bureaucrats to not get taken in with this systematic push to fortified foods. But, this time, their lobbying has succeeded. It will lead to irreversible changes in our food and health systems.”

Public nutritionists have traced how in the last few decades, certain factory-made micronutrients were advanced as an antidote for anaemia and malnutrition, even without complete evidence. Over time, large aid agencies priortised this approach over other diversified food-based strategies. In a well-known paper, “The Great Vitamin A Fiasco”, published in 2010, Michael Latham, a professor of nutrition at Cornell University, and a member of International Vitamin A Consultative Group (IVACG), which is a network of experts and law makers initially created with the support of the United States International Aid Agency(USAID) in 1975, traces how the advocacy by large aid agencies, including USAID, pushed for mandatory supplementation with vitamin A capsules.

Latham writes about the history of the push to addressing malnutrition by splitting it into micronutrients, and the promotion of the a “hidden hunger” concept, even where evidence for its efficacy was incomplete. “‘Three micronutrients were “singled out” as deserving particular attention: vitamin A, iron, and iodine. Although useful in prioritizing problems and drawing attention to the need for action, the identification of these particular micronutrients was somewhat arbitrary, based on an interpretation of data available at that time’”, he quotes David Alnwick, of the UNICEF micronutrients programme, in 1990.

Besides the push towards this by aid agencies, he identified that a major driving force was industry, which is highly concentrated. Between 1999 and 2001, eight vitamin corporations, including Roche(which sold its business to Royal DSM) and BASF had to pay millions in fines in US as well as in Europe after an enquiry found that throughout the 1990s, these corporations had acted as a cartel, colluding to fix prices for synthetic vitamins. Despite this rap, their markets and profits have grown The vitamins market worth USD 3 billion a year in 1999, in the last two decades grew nearly 15 times to over US $ 45 billion last year.

Indian activists’s biggest concern is that industrial fortification shifts focus away from food-based approaches. In his paper, Latham too shows how vitamin supplementation was conceived at the UN initially as only as a temporary measure, pending dietary improvements. But from 1990s, it dominated all other means to improve vitamin A status. In IVACG meetings, he recounted, the findings of studies showing the effectiveness of food-based approaches such as eating green leaves, common tropical fruits to change vitamin status were either not accepted for presentation, or given little attention. 

In 2006, the IVACG, as well as the International Nutritional anaemia Consultative Group (INACG), both of which were then funded by USAID, were incorporated into “The Micronutrient Forum” in the United States, a network to focus on several micronutrients, now substantively(50% of its earmarked funds in 2021) funded by the Gates Foundation. It holds global conferences. 

Latham had criticised its ‘gold’ corporate sponsors of its 2009 convening were Coca-Cola and Pepsi-Co. At its more recent “Connected Conference” in Thailand in 2020, sponsors included ADOB(which makes fertilizers), BASF (which makes chemical fertilizers as well as synthetic vitamins), Sight and Life (a non-profit which continues to be funded by vitamin company Royal DSM and half its board members are DSM personnel), ContractPharma(food supplements firm), and SQM, a Chilean mining giant, among others. 

What was the evidence?

A few months before the FSSAI had notified standards for voluntary fortification of staples for industry, the policy discussion had veered towards anaemia as a problem to be solved by fortification. In a letter to all states of June 8, 2018, then NITI Aayog CEO Amitabh Kant stated that National Nutrition Mission christened POSHAN by Modi on March 8, 2018 “needs to address macro and micronutrients.” He noted that “70% Indians are eating less than half RDA daily needs) of micronutrients..one way is by promoting local millets, fruits and vegetables,” but added, these “may be out of reach of the poorest families.” Instead of detailing what could the government do to support the poorest families to eat local millets, fruits and vegetables, Kant pivots that “a low cost intervention” would be “mandating fortification of food staples.” 

Under the National Food Security Act, passed in 2013 after years of demands by groups such as the Right to Food Campaign to expand India’s food safety net, covers 813 million citizens. Under this, the union government distributes 600 lakh metric tonnes grains annually to the poor, including 350 lakh metric tonnes rice. Starting 2019, the food ministry began pilots to give fortified rice in 15 districts where it supplied five kilos grains per person per month. It proposed giving fortified rice first in children’s schemes, then in the rations scheme in 112 poorest districts, followed by 250 malnourished districts by 2021-2022. Around the same time, NITI Ayog file noting show its officials recommended, these 250 “malnourished” districts “may be re-worded”, calling them “High Burden Districts” instead.

But the pilots did not go well. They did not even take off for the next two years in eight of the 15 identified districts. “The pilot scheme has been rolled out only in 7 out of 15 states. Over a 3 year period there has been a lukewarm response,” Joint Secretary(PFS), DoE again stated in the minutes of the meeting of the Expenditure Finance Committee in September 2021. As a report by The Reporters’ Collective first showed, earlier, on October 9, 2019, the department of expenditure’s note replying to a food ministry letter of September 12, 2019 cautioned that “the proposal for universal roll-out of the scheme from 2023-24 without studying the output/outcome and evaluation of pilot project is pre-mature.” But the other government wings, the FSSAI and the ministry of food and civil supplies pressed ahead, scaling up the pilots. 

Addressing a seminar in October 2021, Sudhanshu Pandey, the then secretary of food and civil supplies department, acknowledged the failure of the pilots, while justifying why they were still scaled up. Pandey explained that the pilots lacked scale as the production of kernels was not there, further, crucial laboratories to test micronutrients were missing. “There were fundamental problems with the pilot…the pilot were purely logistics and supply side related,” said Pandey. In conducting the pilots, Pandey said, it became clear that nearly all the pieces for the policy were missing – he named the supply of fortified rice kernels, the micronutrient mix, that machinery to make and blend the kernels lacked standardisation, and said that what made it more challenging was the sheer diversity of rice grain varieties in India. 

In circular logic, Pandey explained that the officials saw that what they were proposing could not be done, and so they scaled it up, in the process of assuring the producers of a fixed market, to make the scheme a reality despite the lack of progress in pilots. The infrastructure, the “threshold level and maturity scale” were missing, “the ecosystem is not in place”…“The scale was not happening…unless we bring in certainty in the policy itself,” Pandey concluded.

Because the problems in quality of rice kernels have continued despite the attempts to standardize equipment, the government and its “development partners” have since proposed further technical solutions within their approach of tech fixes to hunger. Abhishek Jain of JVS Foods told The Wire that as quality issues of fortified rice kernels, unreliable micronutrient content, adulteration continued to weigh down the scheme, PATH visited their factory in Jaipur to collect data on creating an automated system and was working to create “traceability” of kernels back to manufacturers. Pandey in his address stated that they were working on mandatory “barcoding” gunny bags of rice. The same recommendation was reiterated by the NITI Ayog in its file noting.

Kavitha Kuruganti, an activist with ASHA advocating for sustainable farm livelihoods and farmers’ rights said the government was adopting technical fixes, “as if it is cut from reality of India.”

“It is latching on to silver bullet solutions, heavily influenced by entities such as the BMGF, PATH, but it cannot deny the complexities of development,” said Kuruganti, who investigated the implementation of the scheme in Jharkhand and Chhattisgarh. “The Modi government should instead have listened to members of its own regulatory panels. It should have learnt from the better food-based alternatives by state governments, such as Odisha’s decentralised procurement of nutritious millets, and its program encouraging kitchen gardens.”

Capture of policy-making

Though the Gates Foundation did not respond to queries about its role, its influence on the pilot expansion is explicit in government documents, which mention BMGF as well as its funded entities.

“A detailed implementation action plan will be developed for the pan India expansion of rice fortification with GAIN. GAIN has been chosen as the development partner because it has been chosen as the focal point for all the development partners by BMGF,” states a noting on August 23, 2021 by Vedeika Shekhar, an associate at NITI Aayog.

This note is further followed by, “For development of action plan of universalization of fortification, we may collaborate with GAIN as it is country coordinator for rice fortification for all development partners.” on same date as stated by Hemant Kumar Meena, a Deputy Secretary.  The file noting on fortification further show Arvind Betigeri, who has been head of PATH’s rice fortification project in India, attended these NITI Aayog meetings as a senior consultant.

In its inter-ministerial correspondence, the union government justified the mandatory rice fortification with often inaccurate, or partially accurate claims. In January 2021, memo of expenditure finance committee of food and civil supplies ministry noted the aim of the scheme was reducing anaemia.

But as stated earlier, doctors on the FSSAI scientific panels such as Dr Sachdev said shown that the policy is not appropriate to address anaemia because nearly half the anaemia cases in India are not even from iron deficiency, but other causes. Yet, the food ministry argued for the policy, claiming, “As per WHO, rice fortification with vitamins and minerals including iron reduces risk of iron deficiency by 35% which leads to estimated GDP gain of about Rs 49,800 crore as per FSSAI.”

This WHO guideline of 2018 it relied on, however, had stated a more nuanced and somewhat different finding. It states that eating fortified rice may make no difference to anaemia levels. 

The WHO reiterates the findings of a systematic review of research in health policy, used as a gold standard by research scholars: “The review (Cochrane system review) showed that the provision of rice fortified with vitamins and minerals including iron probably improves iron status by reducing risk of iron deficiency by 35% and increasing the average concentration of haemoglobin by almost 2g/L, but may not make a difference to the risk of anaemia in the general population of those aged over 2 years”. 

It recommended rice fortification with moderate evidence, adding that it requires continuous monitoring, and effective quality control systems. It says such a policy especially needs particular care through public health measures if fortified rice is distributed in malaria-endemic regions, which several parts of Jharkhand, Odisha in eastern India are.

The same WHO guideline thanks Bill and Melinda Gates Foundation along with the United States Centers for Disease Control and Prevention for “financial support for the guidelines development process”, and thanks GAIN for “partial financial support” for a prior meeting on technical aspects of fortification in Geneva on 8-9 October, 2012” with a disclaimer that donors do not fund specific guidelines. (Gates Foundation is the largest non-state funder of the WHO and, in 2021 it was the second largest donor overall. Its growing influence over the WHO was also critiqued during the COVID-19 pandemic that the Foundation’s grants are earmarked contributions and influence, de facto, the priority setting of the WHO.)

Kuruganti, the agriculture activist pointed out the health infrastructure prerequisites such as outlined by WHO should have raised an alarm that the scheme does not fit in neatly in the Indian context at all. “Our safety debates are different from the other regions,” she said. “India is home to many indigenous Adivasi communities, which have a substantial burden of diseases like malaria, tuberculosis, whom this rice may not be suitable for. Yet, fortification has been mandatory in to essential schemes such as food rations, children’s meals. Our socio-economic and cultural context is such that they do not allow these communities to make informed or conscious choices, they then have no alternatives to eating such fortified food,” said Kuruganti.

The complete influence of the Gates Foundation and related entities is also evident in the government guidelines on rice fortification. These reproduced text verbatim from a PATH document. For example, the manual’s page 89-90 state, “No person who is suffering from any contagious or infectious disease is permitted to enter the packing area or touch Ultra Rice.” or ensure “no chance of foreign objects falling into Ultra Rice.” Ultra Rice is a technique invented by the Cox family, an American business, who gifted the technology patent to PATH in 1996-7 which it uses to fortify rice. As per PATH website, the technology is disseminated in poor countries with a US $ six million grant from the Gates Foundation, along with USD 1.5 million from the Abbott Fund, the philanthropy arm of the American nutrition corporation. These excerpts in draft guidelines that showing the copying of the PATH documents were corrected when the guidelines were published in 2019. The term “Ultra Rice” was simply changed to “fortified rice.”

Shrinking budgets

India’s Right to Food Campaign activists have since years opposed use of industrial products such as ready-to-use therapeutic food(RUTF), fortificants in public schemes. They instead advocate for providing local fruits, vegetables, eggs, pulses, millets. But, in the last nine years, funds for social schemes which provide fresh cooked food to children, infants, women have been drastically cut. Development economists Jean Dreze and Reetika Khera calculated that the budget for school mid-day meals, or the PM-POSHAN scheme, is 43% less in real terms than the 2014-15 budget. Similarly, the budget for Integrated Child Development Services (ICDS) scheme, which serves freshly cooked meals at anganwadis or creches to infants, pregnant women, lactating mothers is 40 percent less in real terms than the 2014-15 budget.

Professor Reetika Khera pointed out that of the ICSD budget, Rs 9000 crore was spent on software, equivalent to money that would buy 150 eggs a year for 10 crore children enrolled in the scheme. Commenting on the growing, opaque influence of entities such as the BMGF and its related entities like PATH, she pointed out: “More than 70% of the Poshan abhiyan budget was spent on community events and “real time monitoring” through ICDS-CAS software developed in collaboration with BMGF.”

She expressed wariness over this turn to Gates Foundation-led prescriptions for nutrition. “Earlier, we were concerned about shrinking budgets for social schemes; now increasingly, we worry about conflict of interest in policies, “friendly” research, a revolving door, institutional capture,” she said. “Conflict of interest is now characterized as a “win-win” proposition (“what’s the harm if the private sector profits off reducing malnutrition”)? This undermines multi-lateral agencies and governments – how can they can function democratically when they rely heavily on funds from these few sources?” 

She questioned why instead, local political representatives from among the affected vulnerable communities were hardly invited to policy consultations: “Why are there no village sarpanch, or even ordinary farm workers who are affected on such government committees? Why only these “consultants”?” she asked.  

Read part one here and part two, here.

Anumeha Yadav is an independent journalist reporting on labour and social policy.