Innspill til det totale utkastet mai 2023

From Physicians’ and nutrition association Food for health (Lege- og ernæringsforeningen Mat for helsen)

General comment

Do we need to replace meat or animal protein with legumes or any other sources for protein (or any other nutrients)?

You write on page 61, 62 and 138 and 140:
“To minimize environmental impact, meat consumption should be replaced with increased consumption of plant foods such as legumes.” Why do we need to replace meat?

I suggest to consider following:

1-Contribution of meat to the total intake of f.ex. protein and Iron: How much, or how big part of the total intake of f.ex. protein or iron, comes from meat?

2-Actual intake of protein versus requirement: How much protein does the population consume, and how much protein do we humans need/what is the requirement for protein?

For ex. Norwegian nationwide dietary survey Norkost 3 shows, see table 25b on page 44, shows that meat contributes only with 27% of the total intake of protein, and only with 20 % of the total intake of Iron.

The same survey, Norkost 3, attachment nr. 7.7 on page 66 and 7.8 on page 67 shows that in genereal, the public consumes 80 (women) – 112 (men) gram protein a day. It is almost twice as much as human body needs (0,66 gram x body weight a day).

Because the public in North consumes much more protein that necessary, at least 50 – 90 % more, it is not nesessary to replace meat with any spesial foods.

Men consumes more than enough iron.
Women consumes little bit less iron that recommended.
Coarse grains, and not meat (especially not white meat) are the biggest sources of iron in our diet.
So, it is not necessary to replace meat reduction with anything.

Source: Norkost 3. A nationwide dietary survey among men and women in Norway aged 18-70, 2010-11. The University of Oslo, the Norwegian Food Safety Authority and the Directorate of Health.

Specific comment

Vitamin B12

I suggest to write “if they do not take supplement of vitamin B12” in this sentence         

“The ones who omit or restrict animal products in their diets, as vegetarians and vegans, are destined to become vitamin B12 deficient.”


I suggest to write

“Todays recommendations for intake of protein for vegetarians and vegans are the same as for the general population, because the evidence suggests a similar total protein requirement to those following western vegetarian diets in general.” in the end of the article. Sources:

  1. Mariotti F, Gardner CD. Dietary Protein and Amino Acids in Vegetarian Diets-A Review. Nutrients. 2019;11(11):2661. Published 2019 Nov 4. doi:10.3390/nu11112661   

Quoted: “Therefore, the evidence suggests a similar total protein requirement to those following western vegetarian diets in general [41]”.

“In developed countries, plant proteins are mixed, especially in vegetarian diets, and total intake of protein tends to greatly exceed requirement. This results in intakes of all 20 amino acids that are more than sufficient to cover requirements. In the EPIC-Oxford study, amino acid intakes were estimated in both meat-eaters and vegetarians [24]. “

(24. Schmidt J.A., Rinaldi S., Scalbert A., Ferrari P., Achaintre D., Gunter M.J., Appleby P.N., Key T.J., Travis R.C. Plasma concentrations and intakes of amino acids in male meat-eaters, fish-eaters, vegetarians and vegans: A cross-sectional analysis in the EPIC-Oxford cohort. Eur. J. Clin. Nutr. 2016;70:306–312. doi: 10.1038/ejcn.2015.144.)

  • 2. Melina V, Craig W, Levin S. Position of the Academy of Nutrition and Dietetics: vegetarian diets. J Acad Nutr Diet. 2016;116:1970-1980  Quoted: “Protein  Vegetarian, including vegan, diets typically meet or exceed recommended protein intakes, when caloric intakes are adequate.6-8