133 Molesworth Street
PO Box 5013
Wellington 6140
New Zealand
T+64 4 496 2000
24 April 2026
Alisha Riley
By email: [FYI request #34237 email]
Ref:
H2026080565
Tēnā koe Alisha
Response to your request for official information
Thank you for your request under the Official Information Act 1982 (the Act) to the Ministry of
Health – Manatū Hauora (the Ministry) on 25 March 2026 for information regarding the specific
evidentiary basis for the 2017 fluoride UL update. Please find a response to each part of your
request below.
Under the Official Information Act 1982, I request the specific evidentiary and toxicological
foundation used to justify the 2017 update to the Nutrient Reference Values (NRVs),
specifically the decision to increase the Tolerable Upper Intake Level (UL) of fluoride for
children aged 0–8 to 0.20 mg/kg bw/day.
Please provide the following official information:
1. Skeletal Retention & Demographic Modeling:
Please provide all internal risk assessments, toxicological modeling, or equity evaluations
conducted prior to the 2017 UL increase that analysed chronic bioaccumulation risks for
exclusively formula-fed infants. Please specify if these assessments explicitly accounted
for the disproportionate cumulative exposure on ethnic cohorts with statistically higher
formula-feeding rates (specifically Māori and Pacific infants).
2. The Under-8 Evidentiary Baseline:
Given that the 2009 New Zealand Oral Health Survey excluded children under 8 from
fluorosis diagnostic reporting, please provide the specific contemporary domestic clinical
datasets or epidemiological studies relied upon in 2017 to conclude that doubling the UL
would not inflict severe structural harm (hypomineralization) on this unmonitored
demographic.
3. Safety Benchmarks and Margins:
Please provide the internal policy documents or scientific guidelines justifying the use of
"severe dental fluorosis" as the primary or sole biological benchmark for defining the UL,
including documentation explaining why standard toxic
These parts of your request are refused under section 18(g)(i) of the Act, as the information
requested is not held by the Ministry and there are no grounds for believing this information is
connected more closely with another agency subject to the Act. The National Health and
Medical Research Council (NHRMC) are responsible for developing, reviewing and updating the
Joint Australia and New Zealand Nutrient Reference Values.
4. Internal Communications:
Please provide all internal memoranda, meeting minutes, and communications between
policy/science teams, the NHMRC, and Crown Law between January 2016 and December
2017 referencing the fluoride UL/NRV update. I specifically request any communications
within this timeframe that concurrently reference the pending New Health New Zealand
Inc v South Taranaki District Council litigation.
The Ministry undergone a search of its records and has not identified any documents of
correspondence within the requested timeframe that reference the pending New Health New
Zealand Inc v South Taranaki District Council litigation. Therefore, this part of your request is
also refused under section 18(g)(i) of the Act.
The email trails of correspondence between Ministry officials working in the Nutrition area and
the NHMRC pertain to Minutes and drafts of the final NRV Fluoride supporting documents and
assessment. You can find the updated Fluoride NRVs (2017) through the following link:
www.eatforhealth.gov.au/nutrient-reference-values/nutrients/fluoride-updated-2017. Supporting
documents including the Administrative Report for the Fluoride NRV review can be found here:
www.eatforhealth.gov.au/nutrient-reference-values/resources.
If you wish to discuss any aspect of your request with us, including this decision, please feel
free to contact the OIA Services Team on:
[email address].
Under section 28(3) of the Act, you have the right to ask the Ombudsman to review any
decisions made under this request. The Ombudsman may be contacted by email
at:
[email address] or by calling 0800 802 602.
Please note that this response, with your personal details removed, may be published on
the Ministry website at:
www.health.govt.nz/about-ministry/information-releases/responses-
official-information-act-requests.
Nāku noa, nā
Alex Fuller
Acting Manager, OIA Services
Corporate Services | Te Pou Tiaki
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