We have send input to NNR 2022 here. The text is here. See also: Innspill til NNR-2022 kapittel om B12

The healthy dietary patterns include fish and some dairy products. These foods are the biggest sources of PCB and dioxin pollutants (in the Norwegian diet, for example, despite the fact that Norwegians eat too little fish according to the recommendations.)

Norwegian Authorities, The Norwegian Scientific Committee for Food and Environment (Vitenskapskomiteen for mat og miljø) have this report:

VKM Report 2022: 16 Risk assessment of dioxins, furans, and dioxin-like PCBs in food in Norway
Scientific Opinion of the Panel on Contaminants of the Norwegian Scientific Committee for Food and Environment

Citation of this report, page 28:

“Dioxins and dioxin-like (dl-) PCBs are lipophilic environmental chemicals with long half-lives.
We are exposed to dioxins and dl-PCBs mainly through consumption of foods with high fat content, like meat, dairy products and fish.
Exposure over the years and accumulation in the body may be of health concern.
In the newly published risk assessment from the European Food Safety Authority (EFSA, 2018) the tolerable weekly intake (TWI) was reduced from 14 to 2 pg/kg bodyweight/week.
According to the EFSA report, the European population is exposed to dioxins and dl-PCBs above the new TWI, and the main food contributors of dioxins and dl-PCBs are fish, seafood, meat, egg and dairy products.”

The chapter Dietary patterns – for the Nordic nutritional recommendations 2022 does not deal with how dietary patterns and health outcomes are affected by these environmental toxins.

I ask NNR 2022 to answer the following 3 questions:

How is the status in the other Nordic countries?
Is it necessary and/or benefitial to consume these products just to get the relevant nutrients? The most important contributors to dioxins and dl-PCBs are fish, seafood, meat, eggs and dairy products.”

My suggestion is that it is the healthiest way to get relevant nutrients from food supplements – instead of food with environmental toxins PCBs and dioxins. The other sources of nutrients are:

–EPA and DHA omega-3 fatty acids from seaweed oils (EPA and DHA – they are only essential for pregnant, lactating women and children younger than 2 years).

–Vitamin D from synthetic vitamin D supplements

–Iodine from nutritional supplements or/and enriched food and salt

–Selenium from brazil nuts, sunflower seeds and finally supplements.

If NNR 2023 finds that there are any risks or disadvantages to this choice (substitution of meat, dairy products and fish with alternative sources to include dietary supplements for these nutrients), then:

Which of these foods (meat, dairy products and fish) and in what amounts should be chosen as recommended sources of EPA+DHA, vitamin D, iodine and selenium?

Norwegians eat too little fish according to existing recommendations, and ingest too much PCBs and dioxins. If Norwegians exclude meat, eggs and dairy products, and increase amounts of fish up to the recommended level and intake, will Norwegians get enough EPA/DHA, vitamin D, iodine and selenium?