Public health objection – titanium dioxide, folic acid fortification safety assessment: FOI release

Information requested

1. the full safety assessment and scientific evidence used to re-approve titanium dioxide(E171).
2. the full evidence base and risk assessment used to justify mandatory folic-acid fortification.
3. the risk assessment (if any) for people with MTHFR variants
4. any public-health or economic impact review covering the rise in neuroimmune illness since 2020.
5. a full copy of the exact research and evidence used to override the EU ban (relating to titanium dioxide (E171).

Response

​​​​​Policy Position
On 20 December 2024, Scottish Ministers introduced legislation to require the fortification of non- wholemeal wheat flour with folic acid to help reduce the number of neural tube defects (NTD) affected pregnancies. Mandatory fortification has successfully reduced rates of NTDs in other countries.

Analogous legislation has been laid in England, Northern Ireland and Wales. Fortification requirements will come into force across the UK by the end of December 2026, following a transition period for industry to make the changes.

Thank you for sharing your concerns. You may find it helpful to note  the committee on Toxicity of Chemicals in Food, Consumer Products and the Environment (COT) has carried out an assessment of the dietary exposure of calcium carbonate, iron, niacin and thiamin at current and revised fortification levels. This found that chronic exposures of calcium (as calcium carbonate), iron, niacin and thiamin (for which no change was proposed) from non-wholemeal wheat flour at the current and proposed fortification levels did not exceed their respective guidance levels. The change to the proposed levels of fortification would not result in any material increase in risk of adverse health effects particularly when considering the entire diet and consumption of supplements.

In addition, The Food Standards Agency (FSA) has evaluated the evidence relating to hypersensitivity to folic acid. The FSA concluded that whilst adverse reactions cannot be ruled out, they are likely to be very rare and generally moderate in nature, hence the risk posed is low and the hypersensitivity risk to consumers is deemed to be tolerable. There are currently no reports of hypersensitivity to folic acid in food and the rare occurrences are linked to higher doses of supplements.

Response to your request

​​​​​​​I enclose a copy of some of the information you requested, set out at Annex A (attached separately).

​​​​​​​Most of the information you have requested is already in the public domain and is available online from various websites. I have therefore enclosed details of the information that is available online and links. Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

​​​​​​​While our aim is to provide information whenever possible, in this instance we are unable to provide some of the information you have requested because an exemption(s) under section 38(1)(b)(personal information of FOISA applies to that information.

​​​​​​​An exemption under section 38(1)(b) of FOISA (personal information) applies to a small of amount of the information identified for release because it is personal data of a third party, ie names and/ or contact details of junior members of public sector employees, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018.

​​​​​​​This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

FOI 202500492092 - Information Released - Annex

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