In Response: Getting Your Dose of Vitamin D

In 2009, the International Food Information Council’s (IFIC) Functional Foods/Foods for Health Consumer Trending Survey found that 90% of consumers polled were aware that vitamin D promotes bone health. With increased scientific and media attention stemming from November’s release of the Institute of Medicine’s (IOM) new vitamin D Dietary Reference Intakes (DRIs), today’s consumer is even more aware of the importance of optimal vitamin D levels to maintain bone health, muscle strength, and the immune system.

Americans: A Wide Disparity
Awareness is critical, because an analysis of dietary intake records by the National Health and Nutrition Evaluation Survey (2003-2008) found that more than 90% of Americans in all age groups are consuming less than the 2010 vitamin D DRIs. There are important market opportunities to meet consumer needs, driven by nutrient disparities throughout America.

Regardless of age group, African Americans, and often Latino Americans, have significantly lower vitamin D intakes than do Caucasian Americans (NHANES 2003-2008). Thus, it is not surprising that Appendix I of the IOM’s vitamin D report shows that African Americans and Latinos, such as Mexican Americans, are 5 and 2.5 times more likely, respectively, than Caucasian Americans to have serum vitamin D levels below 40 nmol/L.

According to the 2010 Council for Responsible Nutrition Supplement Usage and Consumer Confidence survey, 80% of Caucasian adults report using vitamin D supplements, versus only 66% of other ethnicities. In addition, while 90% of adults 55 years and older report using vitamin D supplements, only 63% of Americans 18 to 34 years old and 74% of those 35 to 54 years old are attempting to make up for low dietary intakes and a lack of time in the sun. Individuals with annual household incomes less than $50,000 and the unemployed are also less likely to use vitamin D supplements.

Broadening Applications in Food
As awareness of the need for vitamin D builds, I expect to see more manufacturers including this important nutrient in a broader range of foods, beverages, and supplements.

If the new vitamin D DRIs are to be met by dietary means, through food and beverage, FDA needs to change the maximum levels of vitamin D allowed under Generally Recognized as Safe (GRAS) regulations (Table 1) and/or allow more foods to be fortified with vitamin D (Table 2).

In addition, FDA should amend the Recommended Daily Intake (RDI) for vitamin D found in 21 CFR 101.9 and increase the Daily Value (DV) found in 21 CFR 104.20 from 400 to 800 IU/day. On the Nutrition Facts Panel, this would increase the amount of vitamin D required per serving (or Recommended Amount Commonly Consumed, RACC) to be a “good” or “excellent” source of vitamin D. The resultant modification to the Nutrition Facts Panel would provide better guidance to consumers so they could choose foods rich in vitamin D.

However, these suggestions would require FDA to undergo new rulemaking-a cumbersome process further complicated by the fact that standards of identity include fortification levels. Somewhat like asking “Which came first, the chicken or the egg?” regulatory reform is needed to apply new DRIs for vitamin D into labeling laws (e.g., Daily Value) and simultaneously update vitamin D levels used in defining foods (Table 2). As it stands, it will take years before consumers have more food and beverage choices with which to improve their vitamin D intake.

Higher-Dose Supplements
While we may see more fortification in “allowed” foods, it’s likely that for the time being, more consumers will choose to raise their vitamin D intake in supplement form.

Supplements manufacturers, like food manufacturers, must abide by federally regulated Good Manufacturing Practices, but they are not limited in the amount of vitamin D they can include per serving. The IOM moved the Upper Limit (UL) for individuals over the age of nine from 2000 to 4000 IU/day. By raising the DRI and the UL, it is expected that supplement manufacturers will increase the amount of vitamin D in their capsules. However, because FDA has the authority to remove products from the market that are unsafe, I expect to see more dosage increases among lower-dose products and do not expect to see much increase in the already higher-dose range.