Chapter 6. New Zealand's Carbohydrate-Rich Guidelines.

PART II. GOVERNMENT AGENCIES ‘DRAFT OUT’ INDIVIDUAL BIOLOGY & MULTIMORBIDITY

We welcome your use of this resource but please cite:

PSGRNZ (2026) Reclaiming Health: Reversal, Remission & Rewiring. Understanding & Addressing the Primary Drivers of New Zealand’s Metabolic & Mental Health Crisis. Bruning, J.R., Physicians & Scientists for Global Responsibility New Zealand. ISBN 978-1-0670678-2-3

Chapter 6. New Zealand's Carbohydrate-Rich Guidelines.

Part II reviews Ministry of Health and Health New Zealand policies to identify the extent to which nutrition and diet is prioritised across the policy spectrum. The public health role of primordial and primary prevention is outlined and contrasted against secondary and tertiary prevention interventions.

This rapid review of government health policies and white papers reveals that New Zealand’s health policies may mention diet or nutrition but consistently lack substantive content reflecting contemporary scientific knowledge and individual risk factors. Contemporary health policies have not translated into tangible outcomes that have lowered the prevalence of poor, and frequently comorbid mental and metabolic health outcomes.

New Zealand’s legislation emphasises the role of officials in the protection of health. Ministry of Health entities and officials are granted powers under the Health Act 1956 and the Pae Ora (Healthy Futures) Act 2022. At all times they are required to ‘improve, promote and protect public health’.

New Zealand acknowledges that poor nutrition is a modifiable risk factor for poor health. In the

New Zealand’s health budget is considerable, but the percentage dedicated for the research to update existing knowledge bases, to reflect new findings in the scientific literature, to ensure that our policies reflect best scientific evidence, is negligible. Funding to support practitioner and community education for diet and nutrition is negligible. The 2025/2026 budget for the Ministry of Health is $31,052,217,000. Of the $31 billion, $15.7 is budgeted for hospital and specialist services, $9.7 billion is budgeted primary, community, public and population health services and $1.77 billion is targeted for pharmaceutical medicines.[1]

The 2025/2026 budget allocated $6 million for the PHA and the NPHS and $95.3 million to public health and population health leadership.:

‘This category is limited to providing leadership on policy, strategy, regulatory, intelligence, surveillance and monitoring related to public and population health’.[2]

Current New Zealand dietary guidelines for adults recommend 6 servings of grain foods a day and two servings of fruit a day.[3] Pregnant women are advised to consume diets low in only unsaturated fat and eat at least eight servings of cereals a day[4]. The guidelines for children and young people urge four servings of breads and cereals for preschoolers, five servings for children and six to seven servings of breads and cereals per day for young people.[5] Older people are advised to ‘eat plenty of breads and cereals’, 3 servings for women and 5 servings for men a day.[6] Cereals are describe as ‘the best source of energy for the body.’[7]

The guidelines describe T2DM as:

A condition associated with insulin resistance, leading to a relative insulin deficit. It usually develops in adulthood and is caused by lifestyle factors, including obesity. Treatment includes changes to diet, physical activity, weight loss, tablets and/or insulin injections. Sometimes referred to as adult-onset diabetes mellitus or non insulin-dependent diabetes mellitus.[8]

The dietary guidelines do not describe the association of elevated blood glucose levels with risk for insulin resistance, a diagnosis of T2DM and the strong association of elevated insulin levels with obesity. The guidelines simply describe insulin resistance as:

‘The reduced sensitivity of cells to insulin.’[9]

Government guidelines broadly recommending high carbohydrate dietary intakes, do not take into account individual insulin sensitivity, particularly in genetically or metabolically sensitive (e.g. ageing) individuals.

A 2024 Official Information Act request asked two questions regarding carbohydrates and cardiac risk:[10]

Question: Has the Ministry of Health ever reviewed the evidence that partial substitution of carbohydrate with either protein and fats can lower blood pressure, improve lipid levels, reduce estimated cardiovascular risk and reduce pre-diabetes and diabetes incidence?

Response: The Ministry undertook a review of popular diets in 2017 including paleo and very low-carbohydrate diets. The information in this review has now been transferred to Health New Zealand – Te Whatu Ora and can be found on their website at: https://info.health.nz/keeping healthy/popular-diets-review.

Question: Has the Ministry of Health reviewed evidence that current dietary guidelines relating to current recommended levels of breads and cereals in the diet may have potential to increase serum lipids and contribute to the development of pre-diabetes and diabetes? - Pre-schoolers: at least 4 servings - Children: at least 5 servings - Young people: at least 6 servings.

Response: This question was not directly addressed, with Dr Jones instead referring to the 2020 update of current serving sizes which was based on Australian nutrition data from 2013 and earlier. [11]

The government has not reviewed the potential for the cumulative burden of recommended carbohydrate intakes to drive risk for prediabetes and diabetes, and the potential for this to be amplified by ultraprocessed food intake. In a similar vein, New Zealand has been disinclined to identify, regulate and tax ultraprocessed foods and sugar.[12] [13] Ministry of Health guidelines for type 2 diabetes mellitus (T2DM) do not recommend low-carbohydrate approaches.[14] The term ‘metabolic syndrome’ is not recognised by the Ministry of Health.

PSGRNZ’s review of government websites and white pages was unable to identify any budgeted area of policy or policy deployment which were directly concerned with the role of diet and nutrition beyond the production of promotional literature. There are no established bioethics publications specifically addressing whether panels should be ethically required to revisit paediatric carbohydrate guidelines in light of rising prediabetes, T2DM risk and the associated comorbidities. Consensus reviews acknowledge a lack of paediatric carbohydrate alternatives, but they stop short of ethical examination.

As we discuss below in chapter 7-9, neither health policy, health agencies nor science policies build in obligations and explicitly fund ongoing research to keep abreast of the evidence on elevated glucose and unstable insulin levels as a driver of chronic disease, the role of nutrition and toxic exposures to inform policy.

Finally, a series of examples are provided that demonstrate how current policies do not work scientifically or practically, underserving both clinicians and patients.

Chapter 7. Health Targets Decoupled From Policies. No Power to Stop Rising Disease Rates.

RETURN TO CONTENTS PAGE.

REFERENCES

NB: Number order differs from the original Reclaiming Health publication (PDF).

[1] Treasury. Vote Health. The Estimates of Appropriations 2025/26 - Health Sector B.5 Vol.5 https://budget.govt.nz/budget/pdfs/estimates/v5/est25-v5-health.pdf

[2] [2] Treasury. Vote Health. The Estimates of Appropriations 2025/26 - Health Sector B.5 Vol.5 Page 4.

[3] Health New Zealand (2020) Healthy eating, active living. Food and Activity Advice for Adults from 19-64 years. HE code HE1518 https://cdn.accentuate.io/5313685192862/11408390422661/HE1518-healthy_eating_active_living-web_0_Sep2020-v1603943673274.pdf

[4] Health New Zealand (2023). Safe and Healthy Eating in Pregnancy. HE code HE1805 https://cdn.accentuate.io/5313672904862/11408390422661/1.0-HE1805-Healthy-healthy-for-pregnancy_Aug-2023-(1)-v1695958003663.pdf

[5] Healthy Eating for Young People - HE1230 https://healthed.govt.nz/products/healthy-eating-for-young-people

[6] Health New Zealand (2021). Eating for Healthy Older People. https://cdn.accentuate.io/5313672052894/11408390422661/HE1145-HealthyEatingOlderPeople-WEB-Apr-21-v1621897274164.pdf HE1145

[7] Health New Zealand (2023). Eating for healthy children from 2-12 years. Code HE1302 https://cdn.accentuate.io/5313671594142/11408390422661/1.1_he1302_healthy_children_apr_2023_web_0-v1685674014232.pdf

[8] Ministry of Health. 2012. Food and Nutrition Guidelines for Healthy Children and Young People (Aged 2–18 years): A background paper. Partial revision February 2015. Wellington: Ministry of Health. P.181.

[9] Ministry of Health. 2012. Food and Nutrition Guidelines for Healthy Children and Young People. P.177

[10] Ministry of Health Official Information Act Request response. September 4, 2024. H2024048401 https://fyi.org.nz/request/27933/response/107134/attach/9/H2024048401%20Response%20Letter.pdf

[11] Health New Zealand (December 2020). New Serving Size Advice. https://www.tewhatuora.govt.nz/assets/Health-services-and-programmes/Nutrition/new-serving-size-advice-dec20-v3.pdf

[12] Lustig R (2021). Ultraprocessed Food: Addictive, Toxic, and Ready for Regulation. Nutrients 12, 3401; DOI:10.3390/nu12113401

[13] Warhurst L. (October 9, 2019). Jacinda Ardern 'rules out' introduction of sugar tax despite rising numbers of diabetes. Stuff. https://www.newshub.co.nz/home/lifestyle/2019/10/jacinda-ardern-rules-out-introduction-of-sugar-tax-despite-rising-numbers-of-diabetes.html

[14] Ministry of Health and New Zealand Society for the Study of Diabetes. Type 2 Diabetes Management Guidelines Healthy eating and weight loss. https://t2dm.nzssd.org.nz/Section-88-Healthy-eating-and-weight-loss