Australia New Zealand Food Standards Code – Standard 1.3.2 – Vitamins and minerals

Used as a nutritive substance
This term is defined via cross‑reference to section 1.1.2‑12 of the Code. While the definition is not reproduced in this Standard, the Note to this Standard explains that paragraph 1.1.1‑10(6)(b) generally prohibits a substance used as a nutritive substance unless the Code expressly permits it. The concept is central: not every addition of a vitamin or mineral counts; the Standard only applies when the substance is used as a nutritive substance. For example, a small amount of a vitamin present incidentally as an ingredient in a permitted additive would not be caught, but deliberate addition for nutritional purposes would be.

Reference quantity
The definition in section 1.3.2‑2 is twofold. For foods listed in the table to section S17‑4, the reference quantity is either the amount specified in that table (or, for foods requiring dilution or reconstitution, the amount that when diluted or reconstituted produces that specified quantity). For all other foods, it is a normal serving (or, for foods requiring dilution/reconstitution/draining/preparation, the amount that produces a normal serving). This creates ambiguity for foods not listed in S17‑4 because normal serving is not defined within this Standard. It presumably draws on the general Code definition in section 1.1.2‑2, but that definition relies on the concept of a reasonable amount typically consumed in one sitting, which can be contentious in enforcement contexts.

Nutrient Profiling Score (NPSC) and meet the NPSC
The NPSC is defined in section S4‑6 of the Code (not reproduced here). Section 1.3.2‑6 requires that breakfast cereal containing added vitamin D must meet the NPSC, meaning the nutrient profiling score of the food as described in Column 1 of the table to section S4‑6 must be less than the number specified in Column 2. The NPSC scoring system is complex, involving points for energy, saturated fat, total sugars, sodium, and points for fruit, vegetable, nut, legume protein content. For breakfast cereals, this essentially imposes a nutritional quality gate. A high‑sugar or high‑sodium cereal cannot be fortified with vitamin D, even if the vitamin D itself poses no safety issue. This is a substantive restriction that changes the product formulation incentives: manufacturers may reformulate to lower the NPSC rather than simply not add vitamin D, or they may drop the fortification idea entirely.

RDI
The Recommended Dietary Intake is defined in section 1.1.2‑10. It is the benchmark used for claims. The Standard caps claims at a percentage of the RDI per reference quantity, as specified in the table to S17‑4. Notably, the claim cap is independent of the maximum amount permitted. A food could contain the maximum permitted amount, but the claim on the label might be capped at a lower percentage. This disconnects the label statement from the actual content, which may confuse consumers or reduce the marketing benefit of fortification.

Permitted forms (S17‑2, S17‑3)
These schedules list the chemical forms of vitamins and minerals that are allowed. Only those forms can be added. A manufacturer cannot, for instance, add a novel form of iron that is not listed, even if it is bioavailable and safe. This restricts ingredient innovation and supplier choice, potentially increasing costs if only one form is commercially available or if a permitted form is less stable.

Maximum amount and maximum percentage RDI claim
Both are set out in the table to section S17‑4. The maximum amount is expressed per reference quantity and includes natural + added. The maximum percentage RDI claim is a separate column. The Standard gives no rationale for why these specific numbers are chosen (e.g., safety, nutritional equivalence, harmonisation with international standards). Regulatory risk is borne entirely by the food business.

Equation in section 1.3.2‑5
For multi‑ingredient foods, the maximum permitted claim Mrq is the sum over ingredients of either the average quantity (for unfortified) or the maximum claim amount adjusted to the ingredient’s proportion (for fortified). This calculation prevents double‑counting and ensures total claims do not exceed what would be allowed if the food were manufactured from a single ingredient. The rounding requirement (nearest two significant figures) imposes a computational precision discipline.

The primary entities affected are food manufacturers and processors who add vitamins or minerals to food for nutritional purposes. This includes literally any business that makes a fortified food, from large multinational cereal producers to small manufacturers of sports bars, meal replacements, or fortified beverages. The Standard applies across all nine food categories listed in the Note: cereal products, edible oil spreads, infant formula, food for infants, formulated meal replacements, formulated supplementary sports foods, food for special medical purposes, and transitional standard special purpose foods. Each of these categories already has its own product‑specific standard (Standards 2.1.1, 2.4.2, 2.9.1 through 2.9.6). The interaction creates layered obligations: the food must first comply with the category standard, and then additionally with Standard 1.3.2 if fortification is attempted.

Breakfast cereal manufacturers are singled out for vitamin D. They must undergo the NPSC assessment, which is a non‑trivial computational and record‑keeping exercise. This particularly affects higher‑sugar or higher‑sodium cereals that might otherwise benefit nutritionally from vitamin D fortification. The Standard does not permit them to simply reduce the vitamin D amount to zero; the ban applies unless the NPSC is met, effectively forcing either reformulation or abandonment of the fortification.

Manufacturers of meat analogue products are affected by section 1.3.2‑8. Soy leghemoglobin (an iron‑containing protein derived from genetically modified yeast) may only be used in meat analogue products and only at a raw‑state concentration up to 0.8%. This prevents its use in any other food category, such as vegetarian meat alternatives that are not analogues, or in non‑meat foods where iron fortification might be desired. The restriction likely reflects safety‑based considerations given the novel nature of the ingredient, but it also limits commercial expansion for suppliers of soy leghemoglobin.

Importers and retailers are indirectly affected because they must ensure that any fortified food they bring into or sell in Australia and New Zealand complies with the Standard. Due diligence for imported goods requires checking not just label claims but the underlying formulation to confirm total vitamin/mineral levels per reference quantity and compliance with NPSC where applicable. This adds a layer of supply‑chain verification cost.

Compliance professionals and labelling designers must be familiar with the tables in S17‑4 (not reproduced here) to determine permitted vitamins per food type, maximum amounts, and claim caps. The equation in section 1.3.2‑5 must be applied for composite foods, and record‑keeping of the calculations is essential for enforcement preparedness.

Consumers are affected in ways that are not always beneficial. The permission‑based system may reduce the range of fortified products available, particularly in food categories not listed in S17‑4. If a manufacturer wishes to add vitamin C to a food not listed, it cannot, even if the addition would be safe and beneficial. The claim cap may also reduce the information available on labels, forcing consumers to rely on nutrition information panels rather than prominent front‑of‑pack claims. The NPSC requirement for vitamin D in breakfast cereals may push some cereals out of the market or into reformulation, potentially raising prices if reformulation involves expensive ingredient swaps.

New Zealand food businesses are equally affected because the Code is adopted under the Food Act 2014 (NZ) (see Note 2). Any differences in enforcement interpretation between jurisdictions impose additional compliance uncertainty.

Permission to add vitamins and minerals - A food business has the right to use a vitamin or mineral as a nutritive substance provided it concurrently satisfies three conditions from section 1.3.2‑3: (a) the vitamin or mineral is in a permitted form from S17‑2 or S17‑3; (b) it is listed in S17‑4 for that type of food; and (c) the total (natural + added) in a reference quantity does not exceed the maximum amount in S17‑4. This right is not absolute; it is conditional and can be overridden by other provisions of the Code (section 1.3.2‑3 begins “Unless this Code provides otherwise”).

Right to make RDI claims - A food business may make a claim as to the percentage RDI of a vitamin or mineral in a reference quantity, but only up to the maximum percentage specified in S17‑4 (section 1.3.2‑4). Claims above that cap are prohibited even if the actual content is higher.

Obligation to calculate maximum claim for composite foods - Section 1.3.2‑5 imposes a mandatory formula. The food business must determine Mrq using the equation, accounting for both unfortified and fortified ingredients. The obligation is to ensure the claim does not exceed Mrq (rounded). There is no discretion to use a different method.

Obligation to comply with NPSC for vitamin D in breakfast cereals - Section 1.3.2‑6 prohibits the use of vitamin D as a nutritive substance in breakfast cereal unless the cereal as purchased meets the NPSC. This is a substantive hurdle: the NPSC is a dietary‑quality measure, not a safety measure. The food business must compute the nutrient profiling score and ensure it is below the threshold for the relevant food as described in section S4‑6.

Labelling duties for breakfast cereals containing vitamin D - Section 1.3.2‑7(2)(a) requires that if a property of food other than fvnl (fruit, vegetable, nut, legume content) is relied upon to meet the NPSC, that property must be declared in the nutrition information panel if not otherwise required. This imposes additional label real estate and declaration obligations. Under subsection (2)(b), if the cereal scores V points (which relate to fvnl), the percentage of each fvnl element relied on must be declared.

Restriction on soy leghemoglobin - Section 1.3.2‑8(1) gives a limited permission: iron in the form of soy leghemoglobin may only be used in meat analogue products to which S17‑4 applies. Subsection (2) further restricts the concentration to 0.8% in the raw state. The right is therefore narrow and condition‑specific.

Right not to fortify - Food businesses retain the right not to add any vitamins or minerals, in which case this Standard imposes no duties. However, if they choose to make nutrition content claims about naturally occurring vitamins or minerals, Standard 1.2.7 applies separately, and claim caps from this Standard may still restrict high‑percentage claims (section 1.3.2‑4 applies “if a vitamin or mineral has been used as a nutritive substance”; if it is entirely natural, the restriction does not apply unless the food is listed in S17‑4 and the vitamin/mineral is added? Actually, section 1.3.2‑4 applies if a vitamin/mineral has been used as a nutritive substance, so natural‑only foods are not caught. However, the Note cross‑reference to Standard 1.2.7 means general nutrition‑content claims on natural vitamins are regulated elsewhere, which may have similar caps.)

No right to challenge the table - The Standard provides no mechanism for a food business to request addition of a new vitamin/food combination, increase a maximum, or alter a claim cap. The tables are prescribed unilaterally by FSANZ through amendment processes. This gives the regulator complete control over market innovation in fortification.

The Standard itself does not prescribe penalties. Enforcement occurs under the Food Standards Australia New Zealand Act 1991 (Cth) and corresponding state and territory food legislation (e.g., Food Act 2001 (ACT), Food Act 2003 (NSW), Food Act 1984 (Vic), etc.), as well as the Food Act 2014 (NZ) for New Zealand. Contravention of a standard is typically an offence. Under the FSANZ Act, sections 43 and 44 make it an offence to sell food that does not comply with a standard, with penalties that can include fines and, in serious cases, imprisonment for individuals. Corporate penalties can be substantial, often calculated per day of continuing non‑compliance.

Practical enforcement actions include: product recalls for non‑compliant fortified products; infringement notices; injunctions to stop sale; prosecution by state food safety authorities; and adverse publicity. The Australian Competition and Consumer Commission (ACCC) may also become involved if claims are misleading (false RDI claims, for example), under the Australian Consumer Law.

For the specific obligations under Standard 1.3.2, the most likely non‑compliance scenarios are: (a) adding a vitamin/mineral not listed in S17‑4 for that food type; (b) exceeding the maximum amount in S17‑4; (c) making an RDI claim above the maximum % claim; (d) using vitamin D in breakfast cereal without meeting NPSC; (e) using soy leghemoglobin outside meat analogue products or above 0.8% raw; (f) improper label declarations under section 1.3.2‑7; and (g) incorrect calculation of Mrq for composite foods.

The burden of proof for the permission lies with the food business, because the Standard creates an exemption from the general prohibition in paragraph 1.1.1‑10(6)(b). If a food contains an unpermitted vitamin or mineral, it is automatically non‑compliant. The business must be able to demonstrate compliance with all conditions, including the NPSC calculation and the composite‑food formula. Record‑keeping is therefore critical.

In terms of enforcement discretion, regulators may issue compliance tools or warning letters first, but habitual or deliberate breaches can lead to prosecution. The economic burden of a recall (product destruction, lost sales, brand damage) can far outweigh the statutory fine.

No specific enforcement actions or cases are recorded in the source document, so the above is based on general principles of the FSANZ Act and state food laws. The Standard itself provides no internal enforcement mechanism such as audit rights for the regulator; those come from the parent Act.

Standard 1.3.2 does not operate in isolation. It is part of Chapter 1 of the Australia New Zealand Food Standards Code and sits alongside numerous other standards that affect fortification and claims.

Interaction with Standard 1.1.1 (Preliminary Provisions) - Note 3 to this Standard explicitly links to paragraph 1.1.1‑10(6)(b), which prohibits a food from having a substance used as a nutritive substance unless permitted. Standard 1.3.2 is the main permission‑granting standard. If a food contains a vitamin/mineral not in S17‑2/3 or not listed for that food in S17‑4, the general prohibition applies and the food is non‑compliant.

Interaction with Standard 1.2.7 (Nutrition Content Claims) - Note 4 explains that Standard 1.2.7 regulates claims about nutrition content, including the presence of vitamins and minerals. Section 1.3.2‑4 adds an additional cap over and above what Standard 1.2.7 might allow. For example, Standard 1.2.7 might permit a claim of “high in vitamin C” for a certain level, but section 1.3.2‑4 overrides if the maximum percentage RDI claim for that vitamin in S17‑4 is lower. This means a food business must comply with both standards, with the stricter provision prevailing.

Interaction with food‑specific standards - Note 4 lists eight other standards that affect claims about specific foods (Standards 2.1.1, 2.4.2, 2.9.1 through 2.9.6). These may have their own fortification rules, maximum levels, or additional restrictions that go beyond Standard 1.3.2. For example, infant formula (Standard 2.9.1) has its own mandatory compositional requirements; a manufacturer cannot simply rely on the S17‑4 table because the infant formula standard independently prescribes which vitamins and minerals must be present and at what levels. Standard 1.3.2 operates as a supplementary layer: even if the food‑specific standard permits a vitamin, the conditions in this Standard must still be met unless the Code provides otherwise (see section 1.3.2‑3 opening words).

Interaction with Standard 1.2.1 (Labelling) - Section 1.3.2‑7(2) specifies additional labelling requirements for breakfast cereals containing vitamin D: any property relied upon to meet the NPSC (other than fvnl) must be declared in the nutrition information panel. This refers to the labelling provisions set out in Standard 1.2.1. So the label must show not just the mandatory declarations under Standard 1.2.1, but also any additional ones triggered by the NPSC reliance.

Interaction with Standard S4‑6 and S5‑4 (Nutrient Profiling) - These sections (not reproduced here) define the NPSC and V points. A breakfast cereal manufacturer must refer to these sections to compute the nutrient profiling score and determine if the cereal meets the NPSC threshold for its category. The interaction is substantive: the NPSC criteria are not set out in Standard 1.3.2 itself, so compliance requires cross‑referencing to another part of the Code.

Interaction with New Zealand law - Note 2 explains that the Code’s provisions applying in New Zealand are incorporated or adopted under the Food Act 2014 (NZ). While the Standard text is identical, enforcement mechanisms and penalty amounts differ. A food sold in both countries must satisfy both jurisdictions’ enforcement interpretations.

Interaction with trade practices law - False or misleading claims about vitamin/mineral content (e.g., claiming a higher RDI % than permitted) may also breach the Australian Consumer Law (ACL) section 18 (misleading or deceptive conduct) and specific food‑related regulations. The ACCC and state fair trading agencies can pursue separate actions.

No interaction with therapeutic goods law explicitly - The Standard does not mention the Therapeutic Goods Administration (TGA). However, if a vitamin/mineral is added at therapeutic levels (well above Code maxima), the product may be classified as a therapeutic good rather than a food, falling outside the Code altogether. This Standard does not address that borderline; other standards and the definition of “food” in the FSANZ Act apply.

Standard 1.3.2 was originally published in the Food Standards Gazette No. FSC96 on 10 April 2015 as part of Amendment 154 (F2015L00402), with commencement on 1 March 2016. Since then, three amending instruments have been recorded in this compilation (Compilation No. 3, as at 26 March 2021, up to Amendment No. 198).

Amendment 166 (F2017L00023) - Registered 5 January 2017, gazetted FSC108 on 12 January 2017, commenced 12 January 2017. This amendment made two changes: it added a Note to section 1.3.2‑2 (definitions) that included additional definition references; and it added two new sections - 1.3.2‑6 (use of vitamin D as a nutritive substance in breakfast cereal) and 1.3.2‑7 (labelling requirements for breakfast cereals that contain vitamin D). This was a substantive expansion of the Standard to impose a nutritional quality condition (NPSC) on vitamin D fortification of breakfast cereals, along with related labelling duties.

Amendment 168 (F2017L00414) - Registered 11 April 2017, gazetted FSC110 on 13 April 2017, commenced 13 April 2017. This amendment amended Note 3 to the Standard (the note that explains paragraph 1.1.1‑10(6)(b)). It appears to have updated the cross‑reference text, likely to reflect changes in other parts of the Code. It did not change any operative provisions.

Amendment 198 (F2021L00326) - Registered 25 March 2021, gazetted FSC139 on 26 March 2021, commenced 26 March 2021. This amendment added section 1.3.2‑8 (use of soy leghemoglobin as a nutritive substance), permitting iron in that form but only in meat analogue products and subject to a maximum 0.8% concentration in the raw state. This was a targeted permission for a novel ingredient.

The Amendment History table indicates that no subsequent amendments had commenced up to that date. The compilation notes that uncommenced amendments or provisions ceasing to have effect may be reflected as shaded boxed text, but none appear in this compilation.

The pace of amendments - three in six years - suggests that the Standard is relatively stable but open to targeted modifications for specific food‐technology developments. Notably, the amendment to include soy leghemoglobin required a full amendment process by FSANZ, including public consultation and gazettal. This illustrates the exogenous regulatory cost that a food business wishing to use a novel ingredient must navigate: it cannot lawfully use soy leghemoglobin until FSANZ amends the Standard, a process over which the business has limited control.

The source document - the compilation of Standard 1.3.2 - makes no reference to any litigation directly concerning this Standard. The Amendment History, Notes, and operative sections contain no mention of court cases, Tribunal decisions, or enforcement proceedings.

As a subordinate instrument made under the Food Standards Australia New Zealand Act 1991 (Cth), Standard 1.3.2 is subject to judicial review on administrative law grounds (e.g., ultra vires, procedural fairness in the amendment process). However, the absence of any recorded cases in the source suggests that challenges to the Standard itself have not occurred, or at least not been publicly recorded in a way that appears in the official compilation.

Enforcement actions for non‑compliance with the Standard may have been taken by state/territory food regulators or courts, but the compilation does not record those. Practitioners should be aware that unreported magistrates’ court decisions or infringement notices would not appear in this legislative history. The leading cases on food standards generally - such as Australian Competition and Consumer Commission v. Reckitt Benckiser (Australia) Pty Ltd (2016) (involving Nurofen claims) - are not food standards cases, and no specific equivalent exists for fortification.

Given the Standard’s technical nature, litigation risk is more likely to arise in civil disputes over contractual specifications for fortified ingredients, or in trade practices litigation alleging misleading claims about vitamin content that may be linked to the maximum %RDI claim cap. For example, a competitor might sue for false comparison advertising if a product’s label claims a higher RDI % than permitted under S17‑4. But no such case is recorded in the source.

The legal status of the Standard as a legislative instrument means it must be interpreted according to the ordinary rules of statutory interpretation, with the Act (FSANZ Act) as the parent. Any ambiguity in the definitions (e.g., “reference quantity” for foods not listed in S17‑4) could be litigated, but no interpreter has yet had cause to do so, at least in the public record.

In summary, the source does not provide any litigation history, and analysts should not assume the Standard is untested. It may simply be that compliance has been effective or that disputes are resolved administratively without judicial record.

Natural content counts toward the maximum - Section 1.3.2‑3(c) states that “the total amount of the naturally occurring and added vitamin or mineral present in a reference quantity of the food is no more than the amount (if any) specified”. This is a critical and often overlooked trap. A food that is naturally rich in a particular vitamin cannot be additionally fortified with that same vitamin if the sum would exceed the maximum. For example, a breakfast cereal naturally high in folate cannot add folic acid if the combined total breaches the S17‑4 limit. The manufacturer must know the natural baseline, which requires laboratory testing or reliable database values.

Reference quantity confusion - For foods not listed in S17‑4, the reference quantity is “a normal serving”. But normal serving is not defined in this Standard; it draws on the general Code definition, which refers to the amount customarily consumed in one sitting. This is not a fixed number and can vary by product, consumer, and enforcement interpretation. A manufacturer’s chosen serving size may be challenged by a regulator as not “normal”. This uncertainty is a compliance risk.

Composite food calculation traps - The equation in section 1.3.2‑5 uses Qi for each ingredient. For unfortified ingredients, Qi is the average quantity of the vitamin/mineral present in the amount of that ingredient in a reference quantity. This requires knowing the natural content of each component. For fortified ingredients, Qi is the maximum amount that may be claimed for that vitamin/mineral in the reference quantity of the ingredient adjusted to the amount in the food. This is not the actual added amount, but the maximum permitted claim for that ingredient alone. If the ingredient is fortified at less than its maximum, the manufacturer cannot use the actual added amount; they must use the maximum claim amount. This can inflate the total Mrq, potentially allowing a higher claim than warranted, but it also means a manufacturer who under‑fortifies cannot down‑adjust the calculation - the formula treats all fortified ingredients as if they were at the maximum claim level.

Vitamin D NPSC requirement is not a safety measure - The NPSC is a dietary quality index based on energy, saturated fat, sugar, sodium, and fruit/vegetable/nut/legume content. It has nothing to do with vitamin D safety. A breakfast cereal that is otherwise nutritionally balanced but contains a safe level of vitamin D can be prohibited merely because its NPSC score is too high. Conversely, a cereal with a low NPSC (e.g., low sugar, low fat) could be fortified even if the population’s vitamin D intake is already adequate. This substitution effect may not align with public health priorities.

Soy leghemoglobin only in meat analogue products - Section 1.3.2‑8(1) restricts this iron source to “a meat analogue product to which section S17‑4 applies”. If a product resembles meat but does not meet the definition in S17‑4 (e.g., a plant‑based burger with different protein content), it may not qualify. The 0.8% raw‑state limit means the concentration must be measured in the uncooked product, which may be different from finished cooked product levels. Manufacturing losses must be accounted for.

Claim cap vs. amount cap - A food may contain the maximum permitted amount of a vitamin but only be allowed to claim a lower percentage of RDI. For example, S17‑4 might permit 100 mg of vitamin C per reference quantity but cap claims at 25% RDI. The label cannot say “provides 100% of your daily vitamin C” even though the actual content supports it. This can mislead consumers who rely on label claims, and it limits the marketing benefit of fortification, potentially reducing manufacturers’ incentive to fortify to the maximum.

No grandfathering for existing products - The Standard commenced on 1 March 2016. Any product on the market before that date that did not comply would have had to reformulate or be removed. The amendment history does not mention transitional provisions, though other parts of the Code sometimes include them.

Record‑keeping burden - To demonstrate compliance, manufacturers must retain formulations, laboratory analyses, NPSC calculations, and calculations under section 1.3.2‑5. Regulators may request these during inspections or in response to complaints. Inadequate records can lead to inference of non‑compliance.

Compliance with Standard 1.3.2 requires a systematic, documentable process. The following steps are recommended for food businesses intending to add vitamins or minerals as nutritive substances:

1. Determine if the food type is listed in S17‑4. Locate the table in section S17‑4 of the Code. Check whether the specific food category (e.g., breakfast cereal, formulated meal replacement, meat analogue product) appears in Column 1 for the vitamin or mineral you wish to add. If the food type is not listed for that nutrient, fortification is prohibited. If the food type is listed but the vitamin/mineral is not, it cannot be added. Do not assume that because a similar product category is listed, your product qualifies.

2. Use only permitted forms. Verify that the chemical form of the vitamin or mineral you intend to add appears in the permitted‑forms table in section S17‑2 (vitamins) or S17‑3 (minerals). If it is not listed, you cannot use it. If a form is permitted but has a different potency or bioavailability, adjust your addition accordingly.

3. Determine the reference quantity. If your food is listed in the table to S17‑4, use the amount specified in the table (or the reconstituted/diluted equivalent). If not listed, use a “normal serving”. Establish a consistent, justifiable definition of a normal serving for your product, based on typical consumption patterns, and document the rationale. For foods requiring dilution or reconstitution, calculate the amount that produces the specified or normal serving.

4. Calculate total vitamin/mineral content per reference quantity. Sum the naturally occurring content (from raw ingredients or validated database values) and the added content. Ensure the total does not exceed the maximum amount specified in S17‑4 for that vitamin/mineral and food type, if any. If no maximum is specified, there is no upper limit under this Standard (but other standards may impose limits, e.g., safety limits in permits).

5. Cap any RDI claim. Determine the maximum percentage RDI claim from the table to S17‑4. Ensure that any claim on the label (e.g., “provides 50% RDI of vitamin A”) does not exceed that percentage, even if the actual content per reference quantity is higher. If the claim cap is lower than what the actual content would justify, you cannot make a higher claim. Consider using a general nutrition information panel declaration instead of a front‑of‑pack claim.

6. If the food is a composite (multiple ingredients), apply section 1.3.2‑5. Identify each ingredient that contains the vitamin or mineral (naturally or via fortification). For unfortified ingredients, obtain or measure the average quantity of the vitamin/mineral in the amount of that ingredient present in a reference quantity of the final food. For fortified ingredients, determine the maximum amount that may be claimed for that vitamin/mineral in the reference quantity of that ingredient alone (as per S17‑4 for that ingredient), then adjust for the proportion of that ingredient in the final food’s reference quantity. Sum all Qi values to get Mrq, then round to the nearest two significant figures. Ensure that any claim does not exceed this rounded Mrq.

7. Special case: vitamin D in breakfast cereal. Before adding vitamin D to breakfast cereal, compute the nutrient profiling score for the cereal as purchased. Use the method from section S4‑6 (NPSC). The cereal must meet the NPSC, i.e., its score must be less than the number specified in Column 2 of the table to section S4‑6 for that food. If it does not, you cannot add vitamin D as a nutritive substance. If it does, you must still comply with all other conditions (permitted form, maximum amount, claim cap). Additionally, if any property of the food other than fvnl (fruit, vegetable, nut, legume content) is relied upon to meet the NPSC, that property must be declared in the nutrition information panel under section 1.3.2‑7(2)(a). If the cereal scores V points, declare the percentage of each fvnl element relied upon.

8. Special case: soy leghemoglobin. Only use iron in the form of soy leghemoglobin if the food is a meat analogue product to which S17‑4 applies. Ensure that in its raw state, the concentration of soy leghemoglobin does not exceed 0.8%. Document the concentration method (e.g., weight/weight).

9. Maintain records. Keep copies of: (a) supplier specifications for permitted forms; (b) laboratory test results for natural content of ingredients; (c) calculations of total per reference quantity; (d) claim calculations and the basis for any claim made; (e) NPSC score calculations for vitamin D breakfast cereals; (f) records of serving size justification for foods not listed in S17‑4; (g) any declarations made under section 1.3.2‑7. Such records are essential for demonstrating compliance in the event of an audit or enforcement action.

10. Review other applicable standards. Ensure compliance with the food‑specific standard (e.g., Standard 2.9.1 for infant formula) which may impose additional or higher requirements. Also comply with Standard 1.2.7 for nutrition content claims and Standard 1.2.1 for labelling generally. Seek independent legal advice if there is any ambiguity about the interaction between standards.