Chapter 8. Health, Research & Academic Sector: No Pathways for Knowledge.

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

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Under the Health Act 1956, the Director of Public Health is appointed by the Director-General and is required to advise the Director-General of personal health and regulatory matters relating to public health.[1] The Health Act 1956 also provides powers to the Director of Public Health to (after consulting with the Director-General) advise the Minister on any matter, and report to the Minister on any matter relating to public health.[2]

Three entities are primarily responsible for public health in New Zealand.

The Public Health Advisory Committee (PHAC) is an independent expert advisory committee established under section 93 of the Pae Ora (Healthy Futures) Act 2022, to provide public-facing and evidence-based public health advice to Ministers, the Public Health Agency, and Health New Zealand –Te Whatu Ora. Neither the PHAC terms of reference nor the PHAC Position Statement specify any role for nutrition or diet in public health.[3] [4]
The Public Health Agency (PHA) is a division of the Ministry of Health established under section 3 of the Pae Ora (Healthy Futures) Act 2022. The PHA ‘sits at the heart of the Ministry of Health and leads the Ministry’s work on public health and population health’ and is the most important agency for providing advice relating to regulations, to either the Director-General of Health or the Minister. The PHA is required to provide systems leadership across the public health sector and advise the Director-General on matters relating to public health, including –

personal health matters relating to public health; and
regulatory and strategic matters relating to public health.[5]

The PHAs work-scope includes: policy, strategy, regulation, intelligence, surveillance and monitoring.[6] The PHA’s founding document, Pou Whirinaki,[7] mentions ‘equity’ 29 times, but does not mention diet or nutrition. The document states its key functions:

‘The PHA will lead all public health and population health strategy, policy, regulatory, intelligence, surveillance, knowledge and monitoring functions.’

The National Public Health Service (NPHS) is charged with the delivery of public health services, ‘the work on the ground’[8], working ‘alongside communities to deliver national, regional and local programmes for achieving pae ora’.

‘Outside the Work Programme’: Dietary Nutrition’s Impact on Metabolic and Mental Health.

Dietary nutrition is a low priority issue across the Ministry of Health and within its sub-agencies. This was confirmed by Official Information Act (OIA) requests undertaken in 2024. Sub-agency priorities reflect overarching directives with entities adopting a sit and hold consensus positions, rather than engaging in active enquiry to assess new information.

The Public Health Association of New Zealand lacks policy addressing diet, nutrition and metabolic and mental health, despite being responsible for nutrition strategy and updating standards. Information on diet and nutrition mirrors the legacy content on Ministry of Health websites.[9]

A later OIA request confirmed that neither the head of the Public Health Agency nor the top directors-general of the Ministry of Health were briefed on the relationships between dietary nutrition and mental health, the problem of multimorbidity and metabolic syndrome. Work that could assess the relationship of diet with poor mental health is outside the work programme of the Agency.[10] The OIA request revealed that nutrition, diet and the regulatory levels (including recommended and safe levels) of nutrients, including vitamins and minerals, are issues that were all apparently outside the workstreams of Ministry of Health directorates. The PHA’s work programme does not include any undertaking to understand the nutritional or dietary drivers of many common diseases. [11]

The PHA’s work programme reflects the political priorities of sequential governments, and prioritises immunisation, climate change, recognised addictions, fluoridation, and emergency preparedness.

The gap between policy and real-world health risk for the New Zealand population may be observed in the absence of references to metabolic syndrome in official policy. Rates of metabolic syndrome are unprecedented, and metabolic syndrome is framed as a high-risk state, due to the association of the syndrome with increased heart disease, T2DM and mortality risk.[12] [13] [14] [15] Yet in 2024, metabolic syndrome was not formally recognised by the Ministry of Health. Instead, the Ministry of Health viewed the cluster of symptoms characterised by central obesity, dyslipidaemia, hypertension and insulin resistance as either:

‘considered discretely or as part of a broader cardiovascular disease risk calculation. Cardiovascular risk is calculated based on multiple risk factors, set out in the following guidance: Cardiovascular Disease Risk Assessment and Management for Primary Care.’[16]

Officials are unfamiliar with the term metabolic syndrome, and appear to be unaware of the role of carbohydrate-mediated elevated blood glucose (HbA1c) and elevated triglyceride levels as a precursor to metabolic syndrome and heart disease risk. The Ministry acknowledges that macrovascular (cardiovascular) risk increases ‘substantially’ with worsening glycaemic control.: [17]

Microvascular risk increases exponentially and macrovascular risk increases substantially with worsening glycaemic control. The greatest individual benefit is achieved with a reduction in higher levels of HbA1c.

Worsening glycaemic control increases microvascular risk (retinopathy, nephropathy and neuropathy) more substantially than macrovascular risk.

Microvascular disease risk increases progressively from HbA1c levels above the threshold for diagnosed diabetes (48–50 mmol/mol). [18]

However, insulin therapy (a tertiary prevention strategy) is the first line treatment for T2DM. Primordial and primary prevention strategies wherein the Ministry of Health and its associated agencies explicitly recommend a reduction in refined carbohydrates and starchy-foods for the prevention of T2DM and heart health, do not exist. New Zealand’s cardiovascular risk management guidelines for clinicians consequently lack a pathway for clinicians to support patients to lower carbohydrate intake to reduce blood glucose and improve glycaemic control for heart health. The current frameworks suggest that if clinicians actively recommended lower carbohydrate intakes than dietary guidelines recommend, this deviation from guideline recommendations could expose clinicians to investigation.

Government agencies have consistently advanced a consensus perspective, known as the diet-heart hypothesis. This posits that saturated fat and cholesterol are a primary driver of heart disease, and underlies the dietary recommendations for low-fat diets high in cereals, fruits and vegetables. Many government-funded trials have failed to provide evidence to support this hypothesis, and government reviews have failed to incorporate and discuss contradictory data, reflecting long-standing bias towards this issue.[19] [20]

‘Lifestyle modification’ and a ‘healthy diet’ is referred to in government documents, however, dietary management of lipids appears to exclusively concern reducing dietary saturated fat intake to ‘reduce low-density lipoprotein cholesterol (LDL-C) while maintaining or increasing high-density lipoprotein cholesterol (HDL-C)'. [21] Authorities tend to represent lifestyle interventions that induce remission of T2DM as occurring following (downstream) weight reduction, rather than via (upstream) carbohydrate intake reduction.[22]

Insulin was recognised as a fattening substance nearly a century ago. The combination of current carbohydrate-rich dietary guidelines and conventional insulin therapy may act in concert to increase population-level rates of obesity. Historically, naturally produced insulin (from the pancreas) resolved the issue of high blood lipids and enabled fat storage for seasons when food supplies diminished.

Chronically elevated levels of insulin in the blood (hyperinsulinemia), metabolic stress, excessive oxidation and inflammation affect all body systems, from the mitochondria, to the human brain.[23] [24] The common problem of ‘brain fog’ may be driven by elevated glucose and brain inflammation, arising from the over-consumption of carbohydrates. [25] New Zealand’s poor educational performance and poor productivity may be associated with average blood glucose and insulin levels as much as any other factor.

Systemic Neglect of Nutrition and Environmental Health Research.

‘Public health’ refers to the health of all the people of New Zealand, or a population group, community, or section of people within New Zealand, while personal health means the health of an individual. [26] Individuals form the units of any sub-population, and insights from cellular research and single-case studies can inform policy, particularly when they align with evidence from larger cohorts and population-level research.

Therefore, for public health to reflect the state of scientific knowledge, researchers and policy-makers require adequate resourcing to investigate across the full spectrum of scientific evidence: including cellular and mechanistic studies, case reports, cohort studies, and population-level epidemiological research.

Position papers that rely predominantly on epidemiological evidence to justify dietary guideline recommendations may be inadequate for contemporary policy needs. Epidemiological studies are often dated, may omit critical biological or environmental determinants, can conflate effects from multiple exposures, and frequently mask differences in vulnerability across sub-populations. Without incorporating new mechanistic findings and insights from emerging scientific fields, policies weighted heavily toward epidemiology risk being anchored in incomplete or obsolete evidence. As a result, the underlying data may be poorly suited to assessing risk or tailoring benefits at the individual level, which is essential for promoting personal health.

The outcomes of interventions undertaken by clinics represent an opportunity that has yet to be fully pursued. Early-adopter clinics can serve as important bellwethers for policy. Findings generated through clinical audits can highlight how the health status of patients with complex conditions changes over the course of an intervention. The U.K.-based Norwood National Health Service (NHS) Surgery serves as a case in point, having published data tracking outcomes from low-carbohydrate interventions in patients with prediabetes and type 2 diabetes mellitus (T2DM). In a 2024 BMJ editorial, Unwin urged[27]:

I would encourage clinicians working in the field of nutrition to think about publishing audit. In that way we could have vastly more information on interventions that are working well in the ‘real world’. Audit is the way to answer interesting questions about your clinic. For example, do you know the average weight loss, blood pressure improvement or other important clinical metrics achieved by your service?

Outcomes published by the Unwin clinic (discussed below) are yet to be considered by New Zealand health agencies.

Funding for New Zealand–based basic health research falls well short of the scale of the country’s metabolic and mental-illness burden and is insufficient to meaningfully confront the growing challenge of multimorbidity. As this paper was being drafted, the Health Research Council of New Zealand (HRC) communicated that the government was reducing the HRC’s budget by 10% and that this was being ‘repurposed’ to a New Zealand Institute for Advanced Technology which is designed to pursue ‘breakthrough technologies like AI, quantum computing, and synthetic biology’. The HRC was advised that from July 2026 there will be a reduction of $590,000 in the HRC's annual operating budget, and from July 2028 there will be a reduction of $11,487,000 (approximately 10 percent) in the annual investment budget (i.e. the Health Research Fund).[28]

The Ministry of Business, Innovation and Employment (MBIE) controls science and research policy and funding in New Zealand. There is no dedicated, long-term research stream to support high-quality basic and applied public-good research in dietary nutrition, metabolic health, or mental health. In an earlier paper on science-system reform, PSGRNZ outlined how New Zealand’s science system was quietly placed under MBIE’s control through secondary legislation. Members of Parliament did not have the opportunity to vote on the shift from an independent science agency to one primarily oriented toward promoting business and economic growth.

Two years later, in 2015, the National Statement of Science Investment 2015–2025 established a policy platform that, for the next decade, prioritised projects that were ‘innovative’ (with patents treated as a proxy for economic growth) and ‘excellent’ (favouring narrow, discipline-specific expertise). This approach effectively concentrated decision-making for large research investments within small groups of politically aligned actors. At the same time, multidisciplinary public-good research, particularly in environmental science, agriculture, and public health was relegated to short-term, tightly managed, and modestly funded programmes.[29] [30]

Gravida, the institution established to undertake broader research into infant and child health, was defunded and disestablished.[31] The Centre for Public Health Research (CPHR) has long operated with insufficient funding. Limited pathways for environmental and occupational disease research have left CPHR with narrow income streams for essential public-good work.

At first glance, the Public Health Agency (PHA) appears positioned to lead nutrition- and environment-related research, evaluation and education. However, neither its founding documents nor its work programme contain any indication of an intent to review nutrition, investigate toxic chemical exposures, or develop related research capacity.

Since the publication of the National Statement of Science Investment 2015–2025, MBIE has not developed policies or ring-fenced funding to support long-term public-good health research. This gap includes the absence of dedicated funding for dietary, nutritional and environmental-health research or for systems that would allow such findings to be integrated into government policy.

Many research questions that warrant investigation fall outside current funding pathways because they diverge from Ministry of Health guidelines or lack an ‘innovation’ framing. These include long-term studies examining dietary changes across multimorbid conditions such as cardiovascular disease, T2DM, cancer and inflammatory disorders. Critical questions remain unexplored, such as the metabolic effects of diets high in unprocessed fats and low in carbohydrates (under 30% of daily energy), the comparative risks of chemically refined seed oils versus minimally processed dietary fats, and the roles of fat, protein and fibre in satiety and between-meal hunger regulation.[32] [33]

Given the strong association between metabolic syndrome and psychiatric diagnoses, research into how advances in dietary and metabolic health can improve mental wellbeing and resilience is also needed. Likewise, New Zealand lacks any research stream capable of examining the health risks arising from expanding medical prescribing practices, including the extent, impact and effects of polypharmacy among younger populations.[34] [35] [36]

Despite global advances in understanding nutrition, metabolism and environmental exposures, New Zealand has not built the research infrastructure necessary to detect, characterise or respond to environmental determinants of human health risk.

Barriers to Clinical Testing for Toxicity, Genetic Variants and Nutrient Status.

Globally, research unpicking the environmental, including nutritional drivers of human health and disease has increased at pace. [37] Research on human health, diet, and toxic chemical and heavy metal exposures is short term and rare in New Zealand. This spills into limited access to screening technologies for clinical practitioners.

PSGRNZ have identified five systemic barriers that constrain what can realistically be known in clinical practice, limiting the capacity of clinicians and patients to act together in the patient’s best interests. Government commitments to equity ring hollow in this context, as these constraints fall most heavily on low-socioeconomic groups and other population sub-groups who are more likely to encounter toxic exposures, carry particular genetic variants, or live with persistent nutrient insufficiencies.

Public-sector clinicians lack structured pathways to screen for toxic exposures whether dietary, occupational, or urban. It is uncommon for clinicians to order tests even when a patient reports or documents exposure to a hazardous substance. Individuals and families who believe that acute or chronic symptoms may be environmentally driven are often forced into private testing. Domestic human-health screening services are limited, and it is, in practice, easier to obtain toxicology testing for livestock than for people.

Clinicians have minimal access to publicly funded diagnostic pathways, and the few that exist are narrow in scope. Although toxic stressors contribute to a continuum of health risks, facilities to measure biomarkers of exposure, assess toxin burdens, or support research programmes that would build a national evidence base have not been developed or funded.

Public-sector clinicians also lack access to basic genomic screening for common gene variants that influence nutrient absorption and metabolic pathways. Routine testing for variations affecting one-carbon metabolism and methylation capacity, such as the well-characterised MTHFR polymorphisms, is unavailable. Impairments in these pathways can reduce nutrient utilisation and contribute to downstream health effects, yet no accessible clinical pathways exist to identify such risks early.
Clinicians may face scrutiny when they attempt to address optimal nutrition. Routine or repeated testing of nutrient serum levels, e.g. for vitamin D, is sometimes questioned. Moreover, clinicians risk investigation if they recommend intakes above the Ministry of Health’s recommended daily intake levels (RDIs), even though RDIs are designed to prevent deficiency, not to identify or achieve optimal physiological levels for health promotion or disease prevention.
Finally, clinicians must use caution when their prescribing or deprescribing practices diverge from government guidelines. This is the case even when clinical judgement or emerging evidence would support a more individualised approach, as guideline levels focus on deficiency rather than nutrient sufficiency.

Vitamin D is one such example where the health system overstates risk for a basic nutrient while downplaying new scientific evidence. When an OIA request asked for specific nutritional advice for clinicians to support patients on use and dosage of B group vitamins, vitamin C, D, selenium and zinc, the only information that could be supplied were statements on vitamin D and sun exposure.[38]

The Ministry of Health’s 33-page Companion Statement on Vitamin D in pregnancy and infancy[39] under-states the problem and extent of deficiency in New Zealand, providing a new recommendation that was not based on evidence in the scientific literature but on levels recommended by North American and European governments.[40]

The Statement does not engage with the wider biological mechanisms that depend on adequate vitamin D status, instead maintaining a narrow focus on bone-related symptoms. It offers no assessment of the levels required to achieve or correct deficiency. It also overlooks the substantial body of evidence linking subclinical insufficiency with increased risks of cancer, impaired immune function, cardiovascular disease, and metabolic syndrome.[41] The paper recommends a much lower daily intake than is expressed in multiple studies, and neglects to review studies recommending higher intake.

The safety of vitamin D is well established, yet the Statement does not review evidence that higher doses of vitamin D are safe, and did not suggest that the upper limits of 100 μg/4000 IU per day were associated with any detrimental health risk. The paper does not recommend that people are tested for vitamin D insufficiency (unless they experience the symptoms relating to skeletal/bone health).

Current legislation may be obstructing progress in this area. In October 2025, Medsafe released its decision on Professor Julia Rucklidge’s application to raise permitted daily dose limit of vitamin D from 25 micrograms to 75 micrograms (3000 IU), and to allow naturally occurring lithium (at levels commonly present in food ingredients) to be included in nutrient supplements.[42] The Committee argued that her application did not sufficiently demonstrate the benefits of these changes while the risks were not clearly categorised (as these are safe levels of nutrients well-recognised by the body, risks which would be applicable to a medical drug, do not exist).

When PSGRNZ sought clarification, Rucklidge explained that she had been caught in a regulatory Catch-22 within the Medicines Act 1981: the moment any therapeutic benefit is described, the nutrient is automatically reclassified as a medicine, triggering full pharmaceutical regulation and making it impossible to justify nutritional use without simultaneously invoking regulatory medicine controls.

Vitamin D is one case. It highlights the challenges medical doctors face in advising patients on optimum nutrition levels that are required to prevent chronic deficiency. Implicit in this is sufficient information to ensure that the patient has a tangible choice and that the patient, is fully informed. The example of vitamin D levels suggests that chronic deficiency and broader nutritional benefits remain broadly unrecognised by government officials, or not regarded as inside their work programme. These knowledge-gaps bend policy frameworks to favour the prescribing of medical treatments.

Public Health Blindspot: The Addictive Potential of Industrial Ultraprocessed Foods.

In September 2024 the Public Health Communication Centre (PHCC) released an info-paper on ultraprocessed foods. The paper downplayed the health harms and did not discuss the issue that ultraprocessed foods are consistently higher in insulin-spiking carbohydrates, designed for addictive potential, higher in industrially refined chemically synthesised ingredients and associated with food addiction (dependency behaviours relating to sugar and processed foods). [43] [44] The 2024 paper by the PHCC may have been the first time the health sector mentioned ultraprocessed foods on a government-associated website.

Health Coalition Aotearoa’s (HCA) Food Policy Expert Group is an umbrella group which includes public health scientists from New Zealand universities, is yet to confront these issues, focussing more on free sugars and ‘healthy food’.[45] [46] The food and nutrition strategy recommended by the HCA is based on the recommendations of the Public Health Advisory Committee (PHAC) and their work harmonises with the PHCC. The PHAC’s recommendations, documented in the Rebalancing our food system (2024) report drew attention to the ‘out of balance food system’ and discussed the need for a 20% levy on sugary drinks, the challenge of unhealthy food environments and food insecurity. The report did discuss dietary guideline recommendation, nor discuss the addictive potential of junk and ultraprocessed foods.[47]

Approximately 70% of packaged food sold in New Zealand supermarkets is ultraprocessed.[48] Yet, despite the weight of evidence linking these products to adverse health outcomes, neither the Ministry of Health nor Health New Zealand (Te Whatu Ora) meaningfully address ultraprocessed foods in their public material, and the current nutrition guidelines do not mention them at all. Limited research pathways, combined with structural barriers to undertaking independent nutrition research, further constrain knowledge development and narrow the scope for informed policy-making. Without contemporary scientific literacy within the Ministry of Health, and a fluency with the potential of these foods to promote a spectrum of symptom (multimorbidity) it is difficult to see how complex policy approaches could emerge that would shift current burden-of-disease trajectories.

It is similarly unlikely that policy will restrict the advertising of ultraprocessed foods, advertising that disproportionately influences vulnerable groups[49] or support territorial and local authorities to address ‘food swamps’ (areas with a high-density of establishments selling high-calorie fast food and junk food, relative to healthier food options)[50], or the uneven distribution of ‘food islands’ where poorer suburbs have lower levels of choice, less vital food aesthetics, and less healthy foods than in wealthier suburbs.[51]

Data presented in Chapter 4 indicate that many people struggle to limit their consumption of ultraprocessed foods, consistent with evidence that these products are engineered to be hyper-palatable and behaviourally reinforcing. Standard supermarket bread and many common cereals, which contain industrially synthesised ingredients and added sugars, fall squarely within this category.

Food addiction remains unaddressed by the Ministry of Health, and it is improbable that policy leadership on this issue will emerge from within the Ministry. Clinicians who recommend low-carbohydrate diets, that contradict existing guidelines or who advise higher-than-RDI micronutrient intakes risk being challenged by health authorities, even when doing so aligns with emerging evidence or the clinical needs of individual patients. [52] [53]

Global Blindspot: When Health Guidance Focusses more on Climate than on Nutrient Sufficiency.

In 2019 the EAT–Lancet Commission defined food-group ranges for a ‘healthy’ diet and proposed the share of planetary boundaries attributable to food systems as part of a broader agenda for ‘food systems transformation’. [54] The Commission’s claims about what constitutes a healthy and sustainable diet were immediately met with criticism, particularly regarding nutrient sufficiency for specific population groups, including children, young people, and women of child-bearing age. In 2025 the original analysis was updated to ‘expand its scope and strengthen its evidence base’, with the authors asserting that the revised framework ‘positions justice as both a goal and a driving force for a food-systems transformation’.[55]

Although widely celebrated, the EAT–Lancet dietary proposal does not meaningfully examine the micronutrient and neurobiological requirements of children and young adults.[56] The brain is the most nutrient-intensive organ in childhood and adolescence, yet neither the 2019 nor the 2025 paper assesses age-specific dietary needs to support optimal neurodevelopment and mental health. The recommended reduction in animal-source protein is not accompanied by an evaluation of developmental requirements for essential amino acids, omega-3 fatty acids, or B vitamins. These nutrients play well-established roles in neurodevelopment: B-vitamin-dependent methylation pathways shape brain architecture; amino acids underpin neurotransmitter synthesis; omega-3 fatty acids influence neuronal membrane function; and iron, zinc and iodine are critical for cognitive performance.

A substantial group of scholars has highlighted flaws in the EAT–Lancet model and cautioned that issues of nutrient adequacy, cultural acceptability and affordability are yet to be integrated.[57] [58] [59] Reported shortfalls include:

Women of reproductive age: deficient in vitamin B12, calcium, iron, and zinc. [60]
All people aged 6-65 years: deficient in Vitamin A, Vitamin D, Calcium, Iodine, and Selenium. [61] [62]
Underestimating the more complex benefits of nutrient dense whole foods.

The Commission recommended iron supplementation to meet the needs of adolescent girls but did not address the broader supplementation that would be required to ensure optimal brain health should children or young adults adopt the proposed diet.

The Commission also does not address the historical and cultural role of animal products in providing efficient access to key nutrients that support mental health, nor the practical pressures faced by families in which caregivers work full-time and may have limited capacity to prepare nutrient-dense vegetarian meals. Substituting meat with highly refined ultra-processed protein products, often containing additives designed to enhance palatability, may not represent an optimal dietary strategy.

PSGRNZ adopts a more nuanced perspective, recognising that conventional climate-focused sustainability literature seldom addresses the increased agrichemical use associated with horticultural use and large-scale cropping, including heavy herbicide use of glyphosate on Roundup Ready crops.[63] [64]. Sustainability can be more broadly interpreted to include the beneficial impact of well managed (free-range) livestock production for human and planetary health, including an appreciation of the role animals play in sustaining soil health through the fertilisation of soil, and a traditional key role of animals in terrain and/or climatic environments that are unsuitable for cropping.[65] [66]

A recent paper by Leroy et al. (2025) proposes a shift in language from ‘healthy diets’ to an emphasis on adequate nourishment. Many foods considered ‘healthy’ may, in practice, be low in nutritional density. Leroy et al. present a perspective that integrates animal-sourced foods without negating the value of plant-based foods, and they emphasise that certain forms of food processing can support health. The authors highlight the distinction between nutrient density and energy density, noting that ultra-processed foods may be high in calories yet typically

‘do not provide the nutrient richness and biochemical complexity of less processed foods, even when fortified with micronutrients.’ [67]

Leroy et al. weave the priority of nutrient density into a flexible framework that recognises cultural context and the regional realities of agricultural systems.

While consciously refraining from formulating more specific guidance than what is provided by cultural and physiological ‘nutritional wisdom’, we contend that self-selection of dominantly nutrient-dense and satiating foods, which are ideally of a mostly minimally and moderately processed nature … maximizes dietary flexibility according to personal needs and preferences within a broad yet optimal domain for adequate nourishment. [68]

As this paper and our forthcoming work demonstrate, nutrients essential for biological health and with long histories of safe use appear increasingly over-regulated. Officials remain silent on the micronutrient levels required for optimal health, particularly during vulnerable developmental periods. They have declined to examine evidence that challenges the status quo, placing the burden entirely on applicants to persuade regulators that change is warranted. This default approach is a legacy framework designed for corporate applications applying for regulatory approvals for new drugs and medical devices; it is ill-suited to the stewardship of nutrients fundamental to human physiology.

Barriers to knowledge and to affordable access to multi-nutrients disproportionately affect under-resourced communities. As evidence for the role of micronutrients in mental health continues to advance, existing legislation, and the persistent reluctance of the Ministry of Health and Medsafe, may ultimately cause more harm than good for people living with common conditions including depression, anxiety, and ADHD.

Multimorbidity, the co-occurrence of three or more chronic conditions[69], occurs a decade earlier in deprived communities.[70] [71] The societal cost of multimorbidity is super-additive.[72]

Official health literature and communications consistently neglect to address the super-additive cost of multimorbidity, which consistently includes poor mental health. The burden of suffering, disproportionately impact poor communities is antithetical to the requirement in the Health Act 1956 to protect health.

Slightly higher levels of a generic vitamin or mineral intended to restore depleted levels, can be conflated as having the same potential toxic risks as a synthetically developed, patented pharmaceutical drug. The nutrient is essential for biological health; the drug mitigates a symptom that has been diagnosed by a clinician. The institutional and regulatory health system architecture, in addition to legislation that privileges medical drug and device authorisations perpetuates a status quo approach. This approach has set aside the contradictions expressed in the scientific literature on diet and nutrition.

The inability to stem the drivers of chronic illness and multimorbidity is good business for drug companies. A recent survey found a maximum of 53 drugs prescribed to one person. [73] This is costly to the NZ public both in expenditure and health outcomes. The Ministry of Health directorates do not evaluate the cost of multimorbidity by age and gender, together with the increasing prevalence of polypharmacy by age and gender. There is little resourcing directed to understanding the extent of adverse effects experienced by age, gender and by drug category, particularly when it comes to psychiatric drugs. The data are effectively buried.

The absence of information, outdated information and a lack of expertise can lead to mistaken beliefs which implicitly and explicitly benefit drug manufacturers. As the case of vitamin D shows, the New Zealand government overstates risk for nutrients with a strong safety profile. In comparison, psychiatric drug risk is rarely addressed in Ministry of Health literature. For example, there are no 33-page government papers the risk of one psychiatric drug and the risks in pregnancy. A search could locate one paper, The Psychotropic Medications for Mothers and Babies Guidelines, a 24-page document discussing dozens of drugs and their effects.[74] There were no links to the scientific literature to which would enable the reader to understand relevant issues including the study design and the provenance and age of the trial. The extraordinary attention given to vitamin D, and the relative neglect where a review of dozens of psychiatric drugs was condensed into one 24-page paper, highlights how risks from micronutrients tend to be overstated while risks from drugs tend to be understated in Ministry of Health literature.

Patents and trademarks, and the commercial advantages they confer, shape an important part of the wider context. Pharmaceutical patents allow companies to build in margins that cover research, development, and marketing. Officials within Pharmac and Medsafe generally recognise that drug companies conduct controlled trials to generate the data needed to justify an application for entry into the New Zealand market. Yet these trials are typically short, often lasting only weeks to months, while the resulting medications may be prescribed to patients for many years.

In contrast, small and medium sized micronutrient supplement manufacturers struggle to build trademarked protections because of the generic nature of vitamins and minerals and pay the application fees for access to drug markets. Current government frameworks, by failing to address the advantage conferred by the capacity of pharmaceutical and biologic drug manufacturers to patent a medication with margins built in for marketing and drug applications, effectively marginalise and penalise nutrition-based policy.

Dietary approaches: A Survey of the Food/Diet Health NGO Landscape.

Alongside the government health sector, non-government organisations and clinical approaches tend to fall into two distinct categories: one aligns with current dietary guidelines that favour a generous carbohydrate-based intake with reduced intake of fat and animal protein; the other advocates therapeutic carbohydrate reduction and a correspondingly greater emphasis on fat and protein. Both categories strongly support reducing sugar, junk food consumption and consuming whole foods.

Category 1: Alignment with dietary guidelines, low-fat diets and restricted animal protein:

Cancer Society: Harmonises with the New Zealand eating and activity guidelines.[75] Emphasises limits of sugar, ‘fast foods’, red and processed meat and to consume a ‘diet rich in wholegrains, fruit, vegetables, nuts and beans (lentils and legumes)’. Protein and fat consumption is downplayed.

Heart Foundation: Emphasises vegetables and fruit. Recommends that sugar, salt, trans fat and junk food are cut back on. Focusses on reducing fat and limiting egg consumption for a healthy heart. Carbohydrate burdens are not discussed.[76]

Diabetes NZ: Diabetes NZ recognises the direct association of starchy and sweet food with high blood glucose. The organisation adopts the conventional approach that a heart attack is most directly affected by the ‘amount and type of fat and salt you eat’.[77] Carbohydrate intake recommendations revolve around limiting plate portion size to a quarter of the plate, with daily numbers of servings per day of carbohydrate-based foods in the under 50 group recommended at 6 servings of grains, 3 servings of fruit, one cup of milk/yoghurt. Portions of proteins are limited to 2-3 servings, and fat is severely restricted.

The Helen Clarke Foundation: Recommends sugar taxes and restrictions of advertising of products high in fat, salt and sugar, increased restrictions on unhealthy food outlets near schools, increased funding for and improvements in nutrition access for schools, hospitals, the defence force and prisons. Increased investment in weight loss drugs. [78]

Evidence Based Eating NZ: Promotes Whole Food Plant-Based (WFPB) which is vegetarian and does not include added oil. A search could not identify reviews of the scientific literature to identify nutrient requirements by age and gender, including for deficient populations.

Category 2: Low-carbohydrate and ketogenic approaches, support for increased focus on fats & proteins:

WholeNZ: Representative group of individuals and organisations supporting a carbohydrate-reduction approach to reversing pre-diabetes and T2diabetes across New Zealand communities.[79]

The Holistic Performance Institute: Online nutrition and health coach training which considers individual physiology and carbohydrate tolerance. Courses include ketogenic and low-carbohydrate approaches.[80]

Reversal NZ: Founded by Dr Glenn Davies, Reversal promotes a carbohydrate reduction approach to reverse and encourages consumption of low-carbohydrate and ketogenic diets as a dietary approach to reverse, and reduce risk for prediabetes and common metabolic syndrome associated conditions.[81]

Aronui/Turuki Healthcare: NZ-based clinics supporting patients with Lifestyle health coaching/ Health Coaching offering a low-carb approach to support the reversal and remission of prediabetes and T2DM.

Prekure: Health Coach programme training where coaches gain fluency across metabolic and mental health, where low carbohydrate diets and behavioural change strategies are emphasised.[82]

Real Healthy Me: Health improvement programme via a packaged set of appointments at 1-2 weekly intervals, with commitment for a total of 6 months. [83]

The Australasian Metabolic Health Society (AMHS): Provides education, training, and support of evidence-based nutritional approaches, including carbohydrate restriction & ketogenic therapies, as a valid therapeutic option or intervention. Its primary purpose is to develop consensus guidelines, provide education and training for health practitioners in Australia, New Zealand and the Asia Pacific region. [84]

The Heart Research Institute: Healthy Eating Hub, a team of university qualified nutritionists and dieticians discuss the implementation of a low-carbohydrate diet.[85]

ADHD New Zealand: Recognises the combinatory role of starchy foods to add to the carbohydrate burden and elevate blood glucose. Emphasises the importance of protein in the diet.[86]

An increasing group of websites with clinician leadership (that could be identified) that discuss low carbohydrate approaches are online. These include the Low Carb Doctor New Zealand (Facebook group), Liz Ford, Reverse T2 Diabetes Christchurch Keto New Zealand, Low Carb Taranaki, Ketogenic Diet Therapy NZ, and Fearless Nutrition. Other consumer/researcher-developed websites promote low-carbohydrate and ketogenic approaches, including Deborah Murtagh and Keto New Zealand.

When Cumulative Daily Carbohydrate Intakes are Ignored: The $3 School Lunch Programme.

The historic downplaying of the importance of healthy macronutrient fat and protein groups may have been a factor that enabled the National Government to shift quickly to carbohydrate-rich school lunches, such as sandwiches and wraps, mirroring the typical contents of children’s and adolescents’ lunch boxes. While many children have a carbohydrate rich lunch, and then return home to a more nourishing vegetable and protein dinner, the targeting of the lunch programme was explicitly designed to mitigate dietary insufficiency in children and adolescents who are much less likely to return home to a nutrient rich meal, and more likely to return to a calorie-dense but low nutrient meal.

In August 2019, the Labour Government announced that 30 primary and intermediate schools would begin receiving free lunches at the start of the 2020 school year. The trial expanded in 2020 to become Ka Ora, Ka Ako, targeted at the 25% of students living in the lowest socio-economic communities. The plan was to feed 21,000 children in 120 schools by early 2021 as part of the Child and Youth Wellbeing Strategy.[87] By June 2025 this had expanded to feed 242,000 children nationally.[88]

The programme required local providers to supply nourishing meals with a healthy macronutrient ratio, which in practice limited refined carbohydrates and starchy vegetables by ensuring adequate protein and non-starchy vegetable intake.[89]

In October 2024, Cabinet announced major budget cuts to Ka Ora, Ka Ako with the funding for Years 7-13 lunches reduced from $6.99 (Years 4-8) and $8.90 (Years 9+) to $3.2 Schools could continue to use internal model providers (where the meals are made at the school or by a local school on the programme) or remain on the iwi/hapu model if the providers could supply the meals at a reduced price of $4. Lunches remained at status quo for schools with Years 0-6 students. The School Lunch Collective, a consortium formed at the time between Compass Group NZ, Gilmours and Libelle Group, were contracted to take over lunch supply to the remaining 124,941 students on the programme. [90]

In an assessment of lunches provided by the Collective, compared against the national nutrient reference values, the Public Health Communication Centre (PHCC) concluded that:

None of the meals met all the Nutrition Standards for all age groups.’

Meals are very low in energy, providing approximately half of the energy expected for a school lunch and 30-40% less than lunches provided under the previous model.

The $3 cost-effective meals reflect the minimum standards and are predominantly carbohydrate-based.[91] While meat and vegetarian protein is included, the minimum standards are low, 45-75 grams, based on age. Saturated fat is ‘red’, all meat must have fat trimmed or lean, and vegetable oils are ‘green’. Very small quantities (around half a cup) of non-starchy vegetables reflect the established guideline standards.[92]

Where earlier versions of the programme had a broader focus on nourishment and nutrition, the $3 lunch minimum standards are likely to be the supply target for suppliers due to budget restrictions. This shift sidelines a more complex set of aims associated with early food exposure: promoting gastronomy (complex, nutrient-rich foods, including secondary compounds), encouraging seasonal appreciation of foods, fostering dietary diversity, and protecting children from ultra-processed foods and unhealthy eating habits. These aims are central to addressing inequities, as children from wealthier households typically encounter a wider range of foods and develop more varied taste preferences.

European food policies reflect this broader purpose. French school lunches, for example, are designed not merely to ‘feed’ children but to provide a public health and educational intervention that helps establish long-term dietary norms and habits that lower barriers to wider ranges of nourishing whole-foods.[93]

One way nutrient-rich school lunches reduce inequities is by mitigating the impact of economic constraints on the development of children’s taste preferences. Children often reject unfamiliar foods 8 to 15 times before accepting them; expanding dietary variety increases their openness to new tastes and textures. Low-income parents cannot afford to purchase foods that may be discarded if their child refuses them, and children’s taste aversion exerts a strong influence on food purchasing decisions. While children in low-income families may prefer energy-dense, nutrient-poor items, this can reflect intergenerational constraints, parents may have experienced similarly narrow food environments, as well as rational risk-aversion related to food waste.[94]

The default to hyperpalatable, energy dense, nutrient poor foods is a component of the limited control exercised by low-income parents, in making food choices when shopping. This does not necessarily reflect a ‘culture of poverty’, but rather, the financial limitations of food provisioning.[95]

Victoria University research fellow Kahurangi Dey’s evaluation of the initial phase of the Ka Ora, Ka Ako programme (before the budget was reduced to $3) aligns with established literature on the development of taste preferences. Dey noted that children did not immediately accept the healthier lunches containing unfamiliar foods, but that acceptance increased over time.

the transition to nutrition resulted in uneaten lunches. Initially some unfamiliar healthy foods are rejected, but over time, children’s food preferences change as they become accustomed to healthier food. Within six months, the transition to nutrition for children is typically well under way, with previously unfamiliar foods, like tuna or fresh vegetables, becoming accepted. Uneaten lunches are then no longer the issue they were at the beginning of the programme. The graduated approach, with providers slowly adapting from familiar but less healthy options (red and orange light foods) to healthier but initially unfamiliar items (green light foods) that meet nutrition standards, helps improve uptake and promote Ka Ora Ka Ako as reliable and trustworthy.[96]

Studies have since noted that children adapted to new and unfamiliar tastes and flavours and broadened children’s palate acceptances. Reviews have found that the original Ka Ora Ka Ako programme improved mental wellbeing, improved emotional, learning and social functioning, concentration and energy.[97] [98]

It must be noted that since 2011, European policies have been adjusted to reflect climate prerogatives following a 2019 EAT-Lancet Commission on Food, Planet and Health that reduce meat protein consumption[99] (updated in 2025[100]).

Health System Architecture Bias to Consistently Favour Medical Interventions.

Government policies and actions can shape the capacity for public-health research in direct, indirect and often subtle ways. These influences affect what politicians, policy-makers, agency officials, practitioners and patients come to know, and shape the cultural and professional attitudes that produce normative perspectives. In doing so, they can implicitly or explicitly steer attention away from certain topic areas. Such influence can occur at any stage of the research process, from priority-setting and funding decisions to publication pathways and guideline development.

These dynamics help explain why many public-health officials in New Zealand remain primarily focused on meeting screening and immunisation targets, and why the broader health system, from government officials to frontline clinicians, lacks a shared language for metabolic illness, mental illness and multimorbidity.

Social science research draws attention to the human and institutional forces that shape how knowledge is produced, recognised and disseminated, revealing how certain forms of evidence gain visibility while others remain marginalised.

A recent U.S. review shed light on the positive and negative influence of governments on scientific research trajectories. [101] Senior et al (2025) noted:

Importantly, these findings highlight that although it may be intuitive to assume that governments seek evidence that facilitates decisions to improve public health outcomes, other motivations beyond beneficial health outcomes may be present.

The conclusions of this U.S. review are consistent with findings from a comparable New Zealand study.[102]

MODE OF INFLUENCE NATURE OF SPECIFIC INFLUENCE REPORTED [103]

Direct

Preventing or delaying dissemination of findings
Changing information availability
Prioritizing most desirable work
Displaying preferences for output(s) above scientific rigour
Framing of findings
Changing staff involved in the project
Diverting focus away from the project
Controlling access to data, resources, funding, contracts, etc.

Indirect

Using bribery
Threatening job/contract loss
Promoting the concept of research impact
Creating fear of reporting undesired findings
Encouraging research to reach wider policy audiences
Encouraging the use of specific methodologies, approaches, language, dissemination channels, etc.
Using IP as a tool to influence others
Using the credibility of researchers as a divisive tool
Creating relationships with the researchers to allow more influence on the research

Subtle

Promoting societal impact through idealism
Creating an environment where government ideology is shared
Creating job/career insecurity
Promoting a research environment where fear is present

The exploration of policy content and research capacity serves an important purpose in elucidating the very human influence on New Zealand’s political, legal and regulatory health sector – public health. This section demonstrates how brand-new health targets and mental health policy effectively creates barriers to nutritional advice, effectively smooth access to drug-dispensing, effectively corrupting the principle of informed consent. When clinicians and patients lack an adequate understanding of the role of nutrition in supporting mental health, the range of viable options for decision-making narrows. When nutritional psychiatry remains out of the policy equation, care pathways default prematurely to psychiatric medications which are Pharmac funded, effectively dismissing non-medical interventions (which may not be Pharmac funded and/or not included in training programmes).

Without routine assessment of micronutrient status, metabolic health or dietary patterns, potentially reversible contributors to mental distress remain unidentified. For example, improvements may begin with basic measures, optimising nutrition to support sleep, cortisol regulation or energy balance, tailored by age and gender. When these factors are invisible in the clinical encounter, care pathways may default prematurely to psychiatric medications, not necessarily because they are the most clinically appropriate choice, but because alternative explanations and interventions have not been made available.

Informed consent, as defined in health law and ethical practice, requires that patients receive sufficient information to ensure they are fully informed about their condition, the material risks and expected benefits of proposed treatments, and any reasonable alternatives. It also requires that patients are given an opportunity to consider this information and make a voluntary choice. When nutritional and metabolic factors are neither evaluated nor disclosed, the requirements for informed consent cannot be met in substance. Patients cannot provide meaningful consent to psychiatric medication if they have not been informed that modifiable nutritional deficiencies or dietary interventions may constitute viable, lower-risk alternatives or adjuncts. In such circumstances, informed consent is reduced to a procedural formality: the documentation may be completed, but the underlying ethical obligation to ensure decisions are made on the basis of full and balanced information is compromised.

The informational and research pathways that might alter the status quo, have been actively suppressed through MBIE’s science policies that favour research agendas that prioritise innovation-based research with technological outcomes. As a consequence, public good, basic research to elucidate the role of nutrition in the protection of health and prevention of disease across the medical, agricultural and health sciences have dwindled.

Funding incentives and triggers ensure that researchers modify science and research funding proposals to favour ‘innovation’ research and away from research that focuses on a population’s needs. Research can be narrowed around specific topics and methodologies, preventing less ‘desirable’ research from receiving attention. Large research groups and individual researchers will not risk contradicting the policy goal and losing their funding source. Government officials and contracted agencies, then produce policy and health promotion material that is consistent with the preformed agendas handed down by senior staff and officials. Policy agencies commission research that harmonises with preformed policy goals. [104]

The structure and operating practices of these agencies leave little room for internal challenge to long-standing approaches. Moreover, there are no dedicated policies or funding mechanisms to ensure that government agencies undertake transparent, rigorous, and regularly scheduled reviews of the scientific literature, conducted at arm’s length from the agencies responsible for implementing policy advice and interventions. The harmonisation of position statements used elsewhere, in countries with similar disease profiles, is not adequate for government officials who are charged with administering legislation to protect health.

The Medicines Act 1981, procedural norms, guideline rigidity and the absence of research capacity play an important role in perpetuating existing orthodoxies and keeping new evidence at arm’s length. Nutrition-education forms only a relatively small element of medical education while medical prescribing forms a much larger part. [105] In the past, doctors who have deviated from guideline advice have historically been sanctioned by the Medical Council of New Zealand (MCNZ). Following the COVID-19 event, the MCNZ increased sanctioning actions against doctors who failed to follow medical guidelines and who advocated too strongly for dietary and nutritional solutions for certain conditions. This has continued into 2025.

The notion of a single, isolated disease cause is increasingly recognised as the exception rather than the rule. Today, when scientists explore psychiatric, neurodevelopmental, and neurodegenerative conditions they show metabolic and immune system impairment. The question may arise, is it uncontroversial that drug-related research can evaluate the role of, for example, the immune system to understand brain-immune relationships, but it is controversial to highlight the underlying role of nutrition in mediating the immune system and the associative role of the neurological system? For example, scientists exploring drug development recently identified 29 biomarkers that suggest an underlying role of the immune system in a range of seven neuropsychiatric conditions.[106]

It is well established that nutrition is poorly incorporated in medical education ‘regardless of country, setting, or year of medical education’.[107] U.S.-based doctors for example, receive on average, 19 hours of nutritional training. [108] [109] A 2024 survey found that fewer than 22% of surveyed medical schools meet the minimum recommended 25 hours of nutrition education for medical students.[110] A review of medical students and doctors examining why nutrition knowledge is lacking, identified a range of complex drivers, including insufficient curriculum time dedicated to nutrition education, perceptions and confidence, stigmas and health habits, and challenges in clinical practice.[111] The effect is that doctors are unlikely to view nutrition as a therapeutic option for patients and translate the benefits of nutritional research, advice and interventions into medical training and practice.[112]

Avenues for doctors to engage in post-graduate, and continuing, or professional development education are limited. U.K. royal colleges have been criticised for failing to encourage and develop pathways for doctors to study nutrition as an ongoing professional development.[113] Organisations such as the Australasian Society of Lifestyle Medicine (ASLM), the Australasian College of Nutritional and Environmental Medicine (ACNEM) and others, run nutrition-based courses through which medical practitioners can accrue continuing professional development (CPD) or continuing medical education (CME) points, that are approved by the Royal Australian College of General Practitioners (RACGP), Royal New Zealand College of General Practitioners (RNZCGP) and other professional bodies.

The challenge facing New Zealand’s health system is not a simple one. Cultural, educational, structural and informational barriers intersect in complex ways, undermining the ability of Members of Parliament, health-sector agencies, independent practitioners and the public to accurately evaluate and address the drivers of poor metabolic and mental health, and to implement strategies that directly tackle inadequate food quality, nutritional insufficiency and harmful dietary patterns, including those shaped by addiction as well as social, psychological, educational and economic factors.

Is Governance Failing?

A democratic government is responsible for serving the public's best interests. The World Health Organisation, in the preamble to its constitution, sets out this selection of principles about health, which recognises health as having a central role in the public interest:

Health is a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity.

The enjoyment of the highest attainable standard of health is one of the fundamental rights of every human being without distinction of race, religion, political belief, economic or social condition.

The extension to all peoples of the benefits of medical, psychological and related knowledge is essential to the fullest attainment of health.

Informed opinion and active co-operation on the part of the public are of the utmost importance in the improvement of the health of the people.

Governments have a responsibility for the health of their people, which can be fulfilled only by the provision of adequate health and social measures.[114]

From a public and constitutional law perspective, health lies at the core of the public interest. Vote Health is the Government’s single largest area of expenditure, and virtually all aspects of government activity, economic, environmental, regulatory, and social, have direct or indirect effects on population health. In constitutional terms, function should follow form. This paper demonstrates that New Zealand’s current governance arrangements are not fulfilling their intended public function. While the present approach to health policy formulation and implementation is inadequate, it is not immutable; like metabolic dysfunction, institutional failure is capable of correction.

As documented in this paper, New Zealand’s governance structures have, through both omission and commission, increasingly prioritised the interests of the medical and food industries over the public interest. The resulting costs are borne by the public through reduced quality and length of life, alongside the escalating fiscal burden of largely preventable and reversible disease. In this context, New Zealand’s poor population health outcomes and the disproportionate growth in health expenditure may reasonably be viewed as bellwether indicators of wider governance failure.

PSGRNZ advances a set of recommendations aimed at addressing, to a significant degree, the proximate drivers of metabolic and mental illness. However, a genuinely root-cause approach requires more than sector-specific reform. Addressing the entrenched malaise within New Zealand’s health system, where conventional approaches persist despite demonstrable ineffectiveness, necessitates systemic reform of governance structures themselves. Constitutional scholars have long identified structural weaknesses within New Zealand’s governance arrangements and have increasingly emphasised the need for democratic renewal to restore institutional legitimacy and effectiveness.[115]

Governance structures must be capable of delivering on the public interest across all domains, with health recognised as an overarching and cross-cutting priority, rather than a siloed policy outcome. For a democratic system to function effectively, it must incorporate mechanisms that ensure transparency, accountability, and meaningful public participation. This requires institutional arrangements that safeguard sovereignty, reinforce genuine separation of powers, resist excessive centralisation, and limit opportunities for private or commercial interests to compromise public decision-making.

Equally essential is the availability of effective legal accountability mechanisms. Members of the public must have meaningful access to justice, including avenues for scrutiny and, where appropriate, inquisitorial inquiry into proposed policies and into policies or systems that demonstrably fail to serve the public interest. Administrative law, potentially supported by the evolution of a written constitutional framework, offers a coherent legal pathway through which much of the necessary structural and cultural reform could be advanced. [116]

Chapter 9. Type 2 Diabetes: Remission is Real.

RETURN TO CONTENTS PAGE.

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