Their comments respond to FDA proposals that manufacturers should include a percent daily value (DV) for added sugar on the Nutrition Facts panel – set at 10% of total energy intakes (which amounts to 50g sugar, which has 200 calories, ie. 10% of a 2,000 calorie-a-day diet) for Americans aged four and over - in addition to listing the amount of added sugar (in grams).
The FDA acknowledges that biochemically, sugar is sugar - whether it occurs naturally in foods such as fruits or is added to a product such as soda - but says the move will “help consumers make informed choices” and reflects the view of the Dietary Guidelines Advisory Committee (DGAC), which is tasked with advising the government on what Americans should eat, based on the latest science.
The FDA is at a pivotal juncture
However, General Mills said the FDA’s reliance on the DGAC report - rather than working through the established Institute of Medicine (IOM) mechanism of developing daily values for a nutrient - was “unprecedented”, while consumer research consistently showed that shoppers were confused by the new labels.
"The real emphasis should be on limiting consumption of ‘empty calories’ from the major contributors such as sweetened beverages or candy and not on adding another item to the nutrition facts panel wherever sugar might be added. Sugar can be added to increase palatability of a healthy product that provides essential vitamins and minerals and those products are not ‘empty calories’ or items that consumers necessarily need to limit." The Schwan Food Company
“The FDA is at a pivotal juncture because these proposals represent a significant shift in their approach and establishes an important precedent for future labeling initiatives," said General Mills. "FDA nutrition labeling regulations have been based on the totality of scientific evidence, and label revisions have been proposed only after following a rigorous and established process.
“However, it appears that the agency has arbitrarily moved away from this process with these latest proposals. We respectfully ask FDA to pause and take the time needed for a deep, evidenced based review through the Institute of Medicine (IOM) DRI (Daily Reference Intake) process.”
Research conducted by General Mills – which was supported by studies commissioned for the International Food Information Council (IFIC) and the FDA itself - showed that when asked to identify the total sugar content of a product with ‘added sugar’ labeling, just 66% of shoppers answered correctly, compared to 92% of shoppers shown existing labels, said the firm.
“This is a significant decline in consumer understanding,” said General Mills.
“If a product has 20g of total sugar with 0g added sugars, and a comparable product has 15g of total sugar, of which 5g is added sugar, would consumers be able to choose which product best meets their needs if they are looking at overall sugar intake?”
North American Meat Institute
IFIC: New labels confuse shoppers
IFIC similarly agreed that listing added sugars on food labels “significantly reduces the ability of consumers to correctly identify the total amount of sugars in a product”.
FDA research also “illustrates the potential to drive consumers away from products that may contain key ‘shortfall nutrients’ and toward products that may contain ‘over-consumed nutrients’ identified by the Dietary Guidelines”, it claimed.
The National Confectioners Association meanwhile, said establishing a daily value for anything “without the kind of scientific consensus FDA has required in the past would be unusual and arbitrary”, while the North American Meat Institute said singling out added sugars was based on bad science as “there is no difference in the way the body metabolizes naturally occurring versus added sugars.”
"FDA presents no evidence that added sugar is causative in cardiovascular disease (CVD) and presents no mechanism for how added sugar affects or is related to an increased risk of CVD. Unlike other nutrients for which there is a DRV, no clinical studies are cited. The DGAC report uses a food modeling approach, based on USDA food patterns. The subsequent extrapolation of modeling to justify a DRV is scientifically dubious. Canada considered the same science available to FDA and the DGAC and rejected establishing a DRV for added sugar... The European Union has rejected even the labeling of the amount of “added sugars” due to the lack of analytical methods that would distinguish added from naturally occurring sugars."
F. Edward Scarbrough, Ph.D., former director of the Office of Food labeling, CFSAN, FDA, 1990-1997.
In its comment on the FDA’s added sugars proposal, Tate & Lyle argues that allulose – a rare sugar that it has recently launched under the Dolcia Prima brand - should not be listed as an added sugar on the Nutrition Facts label because it contains virtually no calories (fewer than 0.2 kcals/gram), and has no effect on blood sugar or insulin. Listing it as a sugar would therefore be misleading, particularly for diabetics, it says.
NAMI: There is no reliable or accurate analytical method to determine added from naturally-occuring sugars
It was also wildly impractical, said the NAMI, arguing that there is “no reliable or accurate analytical method to determine the difference in types of sugars”, while the American Bakers Association (ABA) said it had conducted a survey of 2,014 Americans aged 18+ and that a “significant portion” believed that ‘added sugars’ contained more calories and were ‘less healthful’ than naturally occurring sugars.
ABA research also revealed that shoppers “mischaracterized a product with less fiber and more total sugars, but no ‘added sugars’… as more healthful and as a better choice for maintaining a healthy weight than a food product with lower total sugars and higher fiber, but containing ‘added sugars’,” added the association.
"Unilever does not believe DGAC reports should be used for the establishment of reference values as this committee is not convened for this specific purpose and intent. There is potential risk that consumers will replace nutritious solid foods (labeled as containing added sugars) such as nut and grain bars with alternatives high in refined carbohydrates." Unilever
Nestlé ‘strongly supports’ added sugar labeling
However, given that the Dietary Guidelines urge Americans to reduce calorie intakes from added sugar, helping them identify foods that actually contain added sugar made perfect sense, said other food manufacturers commenting on the proposal.
Nestlé, for example, “strongly supports ” the proposals, although it wants the FDA to ensure that lactose (milk sugar) and mono and disaccharides from any pure fruit ingredient such as juices, concentrates, fruit pieces, pulps and purees do not count as added sugars “provided that these ingredients are not added for sweetening purposes”.
Nutrition bar maker KIND LLC also welcomed the move, although it says the information “would be more useful to consumers if the amount of added sugars were listed on the label in teaspoons, in addition to grams” – a position shared by the American Heart Association - (which would also like the daily value for added sugars to be lower than 10% - and ideally 5% of energy intakes).
POM Wonderful, meanwhile, supported the notion of listing added sugars on labels, but noted that one bizarre consequence of the FDA proposals as they stand would be that not-from-concentrate 100% fruit juice could boast 0g ‘added sugar’ on the new-look labels, whereas 100% juice made from concentrate (containing an identical amount of sugar) would have to list its sugar as ‘added’.
And this made no sense, said POM: "This may lead consumers to misunderstand the potential health benefits of 100% juice from concentrate."
For more details about the new proposals, CLICK HERE.