I wonder what the source of the nutrition information on FDA labels is. They're not assessing every batch of produce. Is the information we're told about the vitamins and minerals in our broccoli based on crops from last year? A decade ago? A century ago? Is it possible we think we're eating twice as many nutrients as we actually are?
The TLDR is not every food needs to be lab tested as long as they can take their ingredients and compare them against national databases (e.g. NCCDB) to estimate nutritional info. And yes, some of the data in those databases is old and perhaps overly general - it's totally reasonable to suspect that vegetables grown in one area, as part of a specific breeding line, in a certain manner, have totally different nutritional info compared to the same generic vegetable grown elsewhere in a different manner.
However keep in mind a lot of food does not list all micronutrients as part of their labelling. This actually kinda drives me nuts and I have no idea why e.g. frozen vegetables don't list things like Vitamin K, magnesium, and zinc when they're often actually good sources of many nutrients.
It appears the FDA breaks the label down into “mandatory” and “voluntary” categories based on the association of certain nutrients with specific diseases. From your list, vitamin K and magnesium are both voluntary and zinc isn’t included on the standardized label. I assume it’s a business decision by the manufacturer to not include them.
Thanks for linking that, there is a lot of interesting information in that document. They provide a rationale for why each nutrient is mandatory or voluntary as well as public comments and rebuttals.
>One comment suggested vitamin D fortification should be viewed as hormone replacement therapy
If I remember from a Dr. Rhonda Patrick podcast, vitamin D is unique because your body converts it to calcitriol which is a steroid hormone used to treat hyperthyroidism among other diseases.
From that angle, I can understand how they arrive to that conclusion, while perhaps still disagreeing. The interplay within the human body is almost mind-blowingly complex to me