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For reasons that make no sense to me at all, corporations are not allowed to simply make a profit.  Their profits must constantly increase.  They must report growth in profits to Wall Street every 90 days.

For food companies, this is not so easy.  We already have twice as many calories available in the food supply as needed by our population –  nearly 4,000 calories per capita per day.  How to deal with this?  Find new buyers.

General Mills says its “recipe for profitable growth” will target three specific groups: Hispanics, aging baby boomers (those aged 55 and over), and millennials (baby boomers’ kids aged 16-33).  General Mills owns cereals and fruit roll-ups, among other such products.

According to MinnPost.com, General Mills is now the leading advertiser in U.S. Hispanic media.

But General Mills expects most of its growth to come from emerging markets like China.  Sales in China tripled from 2005 to 2009 and are expect to reach $900 million by 2015. Sales of General Mills’ Häagen-Dazs* ice cream are booming in China.

Isn’t it fun to be a target of General Mills’ growth strategies?  I assume all major food companies have their eyes on the same target.

*Factoid footnote: Nestlé owns Häagen-Dazs in the U.S. and Canada.  General Mills owns the brand everywhere else, including in China.

I went to the reception last week for Diet Coke’s red dress event,:

Diet Coke and the National Heart, Lung, and Blood Institute (NHLBI) of the National Institutes of Health have joined forces to raise awareness about women’s risk of heart disease — in support of NHLBI’s The Heart Truth campaign — with a multi-faceted program that will reach consumers across the nation.

To celebrate American Heart Month in February, Diet Coke’s Red Dress Program will take center stage at high-profile events, including sponsorship of The Heart Truth’s, Red Dress Collection fashion show at Fashion Week 2008. Diet Coke will also unveil new packaging and programs featuring The Heart Truth and Red Dress logos and messages on heart health.

The Center for Science in the Public Interest points out that Coca-Cola, whose products are not exactly heart healthy, is a strange partner for the NHLBI.  The agency should reconsider.  It wrote NHLBI to say so.

New York Times reporter Tara Parker-Pope asks: “Should Coke talk about heart health?”

I don’t know how long Diet Coke and NHLBI have been engaged in this partnership but it is surely more than five years.  From NHLBI’s point of view, the partnership publicizes the risk of heart disease to women.  For Coca-Cola, the benefits are obvious.

Are such partnerships a benign win-win?  History suggests otherwise.  In 1984, Kellogg cooked up a partnership with the National Cancer Institute to put health claims for fiber on the boxes of All-Bran cereals (I discuss this incident in Food Politics).  In doing so, Kellogg (and NCI) went around the FDA and undermined that agency’s control over health claims on food packages.  This let to the current mess over health claims, which the FDA is now trying to clean up.

Update March 3: The Public Health Advocacy Institute at Northeastern University has filed a petition to NHLBI to give up the partnership.

To anyone following the ins and outs of food industry “self-regulation” of marketing to kids, here is a gift – courtesy of Margo Wootan of Center for Science in the Public Interest (CSPI).  Margo forwards a set of background papers and speeches on the topic.  I’ve posted some of these earlier, but it is good to have them in one place.

1. The study of food marketing by Dale Kunkel for Children Now

2. Elaine Kolish’s December speech in response to the Children Now study.  She is the head of the industry kids’ self-regulation unit at the Better Business Bureau.  Her conclusion: self-regulation is working.

3. The Rudd Center’s cereal marketing study summary

4. CSPI’s studies on food industry self-regulation

Enjoy, but also put to good use!

Thanks to my NYU Medical Center colleague, Dr. Melissa Bender for the alert about the blogosphere fuss over Cascadian Farm Purely O’s cereals.  Apparently, Cascadian Farm, now owned by Big Food General Mills:

quietly changed the recipe for its “Purely O’s” cereal — previously an unsweetened favorite among children/toddlers – to include three times the sugar, as well as new fillers/sweeteners such as corn meal and tapioca syrup. They did this with no announcement on the label, taking advantage of those who trusted the brand for its previous simplicity. Loyal customers, particularly parents who had chosen this product because it was one of the few unsweetened options available, are outraged by this secretive yet major reformulation. Many discovered the change when their children spat out the cereal (myself included).

Her note sent me right to the largest of the three Whole Foods stores within walking distance of my Manhattan apartment.  Purely O’s: 3 grams of sugars, 3 grams of fiber, and 160 mg sodium per serving.

Oops: low-sugar, yes, but only medium-fiber and high in sodium.  Even with 0 grams of sugar, it’s not all that great.  Neither, for that matter, is its non-organic analog Cheerios (1 gram sugar, 3 grams fiber, 190 mg sodium).

At 3 grams of sugar per serving, Purely O’s is still lower in sugar than practically every other cereal in Whole Foods.  Whole Foods does not sell Big Food non-organics, so it does not carry Cheerios.  I had to look hard to find the only cereal lower in sugar than the reformulated Purely O’s: Arrowhead Mills Shredded Wheat, Bite Size (2 grams of sugar, 6 grams of fiber, and only 5 mg sodium).  That one, it seems to me, is a much better choice to begin with, pretty much in the same category as oatmeal (1 gram of sugar, 4 of fiber, and 0 mg sodium).  When it comes to cereal, more fiber the better.  Fiber is the point of breakfast cereal.

So I can’t get too upset about the reformulation of Purely O’s.  It’s simply a business decision, entirely to be expected from Big Food.  Cascadian Farms started out with “humble beginnings” as a maker of organic products, none of them cereals.  It was successful enough to be bought first by Small Planet Foods, and later by General Mills, which wanted to get in on the organic market.  Hence: organic Purely O’s.

General Mills is in business to sell cereal, and Purely O’s just didn’t make it past focus groups, as reported in the Boston Globe earlier this year.  General Mills must think there are too few of its deeply loyal customers to matter.  According to a business school case study, it has a history along these lines.  So chalk this one up to corporate imperatives.

Dr. Bender wrote to General Mills and received a reply that said as much:

Our goal is to give consumers quality products at a good value. Prior to introducing any product, extensive consumer testing is done. We conduct market research and product testing continuously to obtain consumer reaction to existing products and to changes being considered. Only when we feel confident that a product change will broaden its appeal will we alter a product’s formulation. We are sorry that you do not agree that the recent change in Cascadian Farm organic Purely O’s cereal was for the better.

If the bloggers are looking for a replacement, try oatmeal or those cute little bite-sized shredded wheat things.

It’s been quite a while since Eating Liberally’s kat had a question for me, but this one certainly got my attention.  My book about pet food with Malden Nesheim, Feed Your Pet Right, has just progressed past its second set of page-proof corrections and is slowly making its way to publication on May 11.  Here’s her question:

Let’s Ask Marion: Is Fido The New Hummer?

Submitted by KAT on Tue, 12/22/2009 – 8:13am.

I received a flurry of “you should have attended the meeting before you said anything” messages in response to my post yesterday about the FTC forum.  They said the table that I posted did not have footnotes attached and I also had missed a key point about RACC (reference amounts commonly consumed): they are likely to be larger than current FDA serving sizes, meaning that the amounts of sugars and salt will have to be reduced to qualify.

Guilty as charged.  RACC, as I mentioned yesterday, is a new term to me.  This is because – how could anyone have missed this – I was unaware of the FDA’s Federal Register notice of April 4, 2005: “Serving sizes of products that can reasonably be consumed at one eating occasion; Updating of reference amounts customarily consumed; Approaches for recommending smaller portion sizes.”

This notice was the result of concerns about the serving sizes that had been established when the FDA issued final food labeling regulations in 1993.  Then, the FDA established serving sizes for 129 product categories for adult foods and 11 categories for infant and toddler foods.  These were derived from information about amounts commonly consumed reported in food consumption surveys from the late 1970s and late 1980s.

Either people ate a lot less back then or they were lying, or both.  As my former doctoral student, now Dr. Lisa Young, discovered during her doctoral research, standard portion sizes – half a cup of ice cream or one 2 or 3-ounce slice of pizza, for example – are smaller (sometimes much smaller) than what people seem to be actually eating.

The FDA knew this.  In 2003, it appointed an Obesity Working Group to advise the agency about several issues, among them whether to update the RACCs.  The Group filed its report in 2004.  With respect to serving size, it recommended:

* In the short-term, that FDA encourage manufacturers immediately to take advantage of the flexibility in current regulations on serving sizes that allows food packages to be labeled as a single-serving if the entire content of the package can reasonably be consumed at a single-eating occasion.

* In the long-term, that FDA develop two separate ANPRMs [Advance Notice of Proposed Rulemaking].  The first would solicit comment on whether to require additional columns within the nutrition label to list the quantitative amounts and %DV of the entire package on those products and package sizes that can reasonably be consumed at one eating occasion or, alternatively, declare the whole package as a single serving. This ANPRM would also solicit information on products and package sizes that can reasonably be consumed at one eating occasion.  The second ANPRM would solicit comments on which, if any, RACCs of food categories appear to have changed the most over the past decade and therefore need to be updated.

On that basis, the FDA’s 2005 Federal Register notice asked for comments about whether:

• Consumers might “think that an increase in serving size on food labels means more of the food should be eaten.”
• Manufacturers might repackage products in larger sizes to avoid labeling a package as a single serving.
• Manufacturers might reduce the size of single-serving packages to reduce the apparent content of undesirable nutrients.

That was nearly five years ago.  If anything further happened, I cannot find it in the Federal Register. Getting to these questions at last was apparently the point of the FTC forum.

I am told that panelists suggested raising the RACC serving size of kids’ cereals to 50 grams rather than the current 30 grams.  If so, this would require cereal companies to reduce the amount of sugars in their products.   Aha!  That could explain why, as I discussed in a previous post, General Mills chose to put its full-page ads in newspapers promising to drop the sugars to single digits.  General Mills must think changes in the RACC for cereals will require it to lower the sugars in order to be able to advertise to kids under the voluntary guidelines. Given how long the FDA’s processes take, it is understandable why General Mills failed to say when it would implement its promist.  I am also told that the salt cut-point is open for comment.

For those of us who were not at the Forum and prefer to see such things in writing, how about releasing the footnotes to that chart and giving us some examples of the proposed changes to the RACC?  Also, how about setting up a mechanism so interested people can file official comments on the proposals?  Both would help people offer more informed comments on how the FDA should handle the serving size issues.

Update, December 20: Thanks to Ellen Fried for providing a link to some food industry opinion on what all this is about and another an in-the-know source that says the proposed standards are to be published in the Federal Register and opened for further public comment in January.  The project is to be finished by July.  Ellen points out that this procedure seems administratively complicated for standards that are not regulations; they are voluntary. Do the FTC and FDA really have to go through all this to issue what is simply guidance?  Or is something else going on here that I’m not getting?

I could not go to the Federal Trade Commission’s December 15 forum on food marketing to children (see previous post), but from all reports I missed quite a show.

Officials of four federal agencies involved in food and food regulation – FTC, FDA, USDA, and CDC – released the results of their collaborative efforts to set standards for marketing foods to kids through an Interagency Working Group on Food Marketed to Children.  Congress established this group through the 2009 Omnibus Appropriations Act.  It specified that the group was to set up standards for identifying foods that should not be marketed to children and to publish them by July 15, 2010.

And what standards did the four agencies come up with?  Here are the working group’s recommendations:

Take a look at these “Tentative Proposed Standards for Marketing Food to Children 2-17” and decide for yourself whether they are even remotely meaningful.

The Standards are divided into three categories: Standard 1 is real (largely unprocessed) foods with no added sweeteners or functional ingredients.  These could be marketed to children with no further scrutiny.

Foods that do not meet Standard 1 would be required to meet both Standards 2 and 3 in order to be marketed to children.

Standard 2 applies to foods that “must provide a meaningful contribution to a healthful diet” in one of two ways: containing 50% by weight of real foods (Option A), or by containing defined amounts of some useful nutrients per RACC (Option B).  RACC is a new term to me.  Apparently, it means “reference amount customarily consumed.”   I have no idea what these are but let’s call them serving size.

And what about the cut points?  No foods marketed to children can exceed Standard 3 (“nutrients to limit”):

• Saturated fat: 1 gram or less per serving and not more than 15% of calories
• Trans fat: less than half a gram per serving
• Sugar: no more than 13 grams per serving
• Sodium: no more than 200 mg per serving (equivalent to half a gram of salt)

Got that?  It’s enough to make me weep.

Apparently, the agencies did not give examples of products that might qualify or not, so you have to do your own work on this.  So that leaves me with some questions about the tentative proposed standards:

• Which products qualify and which do not?  It looks to me like the criteria will continue to permit the marketing of questionably nutritious products to kids.  Sugary kids’ breakfast cereals should easily qualify; most do not contain more than 13 grams of sugars per serving or more than 200 mg sodium.
• What is the definition of RACC?  I don’t see a definition in the document.  Without a definition, are companies permitted to define serving sizes for themselves and, maybe, reduce the stated serving size to meet the standards?
• Is there any accountability for meeting the standards?  The entire program is voluntary. Alas, we have already had years of experience with industry “self-regulation” and know that it does not work.

This is the best government agencies could come up with?  I see this as further evidence for the need to stop companies from marketing foods to kids.  Period.

Or am I missing something?

A new study from the U.K. suggests that traffic-light labels on food products are not inducing people to choose healthier options.  The study contradicts the results of a previous study by the British Food Standards Agency, which found the traffic-light labels to be preferred by consumers, of use to them, and a stimulant to manufacturers to reformulate products to qualify for more of those little green dots.

While the arguments go on, and the FDA and the Institute of Medicine conduct their own studies of front-of-package labeling, and the FTC establishes its own standards for advertising, I have a suggestion: How about removing ALL health and nutrition claims from junk foods.

How about trying to think about foods as foods, not drugs.  Let food packages carry Nutrition Facts labels and lists of ingredients, but that’s all.  It would save everyone a lot of trouble.  Federal agencies could get back to worrying about more important things.  City and state attorneys could too.  And consumers would no longer be misled by absurd claims that cereals or snacks will make people healthy.

Just a thought.