Currently browsing posts about: Labels

Michael Specter’s article “Seeds of Doubt” in the current issue of The New Yorker  is a critical profile of  India’s Vandana Shiva and her active opposition to genetically modified foods.  At the end, it offers this somewhat temporizing statement:

Genetically modified crops will not solve the problem of the hundreds of millions of people who go to bed hungry every night. It would be far better if the world’s foods contained an adequate supply of vitamins. It would also help the people of many poverty-stricken countries if their governments were less corrupt. Working roads would do more to reduce nutritional deficits than any G.M.O. possibly could, and so would a more equitable distribution of the Earth’s dwindling supply of freshwater. No single crop or approach to farming can possibly feed the world. To prevent billions of people from living in hunger, we will need to use every one of them.

Despite this peace offering, his article elicited a firm rebuttal from Dr. Shiva. It also elicited a rebuttal from Gary Hirshberg, chair of Just Label It. If you want to get into the weeds of the GMO arguments, all three of these pieces are well worth reading.

They raise and debate the same arguments I discussed in Safe Food: The Politics of Food Safety, first published in 2003 and out in a second edition in 2010. As I explain in the book, the gist of the arguments comes from two apparently irreconcilable views of GMO foods:

1. The “science-based” position: If GMOs are safe (which they demonstrably are), there can be no rational reason to oppose them.
2. The “societal value-based” position: Even if GMOs are safe (and this is debatable), there are still plenty of other reasons to oppose them.

Specter holds the first position.  Shiva and Hirshberg hold the second. Those who hold the “science-based” position would do well to take societal values more seriously.

Seed patents, monoculture, weed resistance, and other such concerns trouble people who care about food systems that promote health, protect the environment, and provide social justice.

Labeling, right from the start, would have acknowledged the importance of such values. Until GMO foods are labeled as such, the same arguments are likely to go on endlessly, with no reconciliation in sight.

Additions:

• August 27   The Nation on “Can GMOs help feed a hot and hungry world?”
• September 2  David Remnick, editor of the New Yorker, has written a letter in response to Dr. Shiva’s rebuttal.

Food Navigator—USA’s Elaine Watson just put together a special edition on the revamping of the Nutrition Facts label.  Her title: Radical overhaul or a missed opportunity?

To understand what’s happening with food labels, you can start with the FDA’s home page on its proposed revisions.  The comment period has ended.  You can read the comments that have been filed on the Nutrition and Supplement Facts panels, and those filed on the proposed changes to the standards for serving sizes.  These are fun to read; opinions, to say the least, vary.

But back to Food Navigator, which collects in various pieces on the topic in one place.  The “Radical overhaul” piece contains a summary of the major provisions.  Others in the series are also useful (I’m quoted in some of them):

Does vitamin D belong on the Nutrition Facts panel?

FDA proposals to list “added sugars” on the Nutrition Facts panel have already generated heated debate, so it’s perhaps unsurprising that its plan to include vitamin D is proving equally controversial…

Should ‘added sugars’ be listed on the Nutrition Facts panel?

A row is brewing over the merits of including ‘added sugars’ on the Nutrition Facts panel, with critics arguing that our bodies don’t distinguish between ‘naturally occurring’ and ‘added’ sugar – and neither should food labels – and supporters saying it will help consumers identify foods with more empty calories.

 Nutrition Facts overhaul is a missed opportunity for long chain omega-3s EPA and DHA, says GOED

The FDA’s overhaul of the Nutrition Facts panel misses a public health opportunity by prohibiting firms from even highlighting long chain omega-3 fatty acids EPA and DHA on the panel, says GOED.

What are the biggest contributors of added sugars to the US diet?

Check out this analysis of NHANES data to see where our added sugars are coming from plus read new comments about the ‘added sugars’ labeling proposal from Ocean Spray cranberries and others.

Former FDA commissioner: Nutrition Facts overhaul doesn’t go far enough

FDA proposals to overhaul the Nutrition Facts panel on food labels don’t got far enough, says former FDA commissioner David Kessler, M.D.

Behavioral scientists: Changing serving sizes on Nutrition Facts label could have unintended consequences

FDA proposals to change the way serving sizes are calculated to better reflect real-life eating behavior could encourage some people to eat even more unless the wording is changed, says one expert group.

Until phosphorus gets on the USDA’s radar, labeling policy won’t change: NKF

While phosphorus is an essential nutrient found naturally in some foods such as egg yolk and milk, it is increasingly added to packaged foods via a raft of phosphorus additives, and some experts believe it should be listed on the Nutrition Facts panel.

Canada’s proposed Nutrition Label changes emphasize calories, sugar

Health Canada is proposing changes to nutrition labels that would make them easier for consumers to read.

RD: There’s a health continuum for every food; what pillars do you want to stand on?

Rachel Cheatham, RD, founder of nutrition strategy consultancy FoodScape Group, talks food labeling at the IFT show.

Is your product ready for nutrition label changes?

“A 16-ounce drink and a two-ounce bag of potato chips are a single serving. If it’s bigger than that, from 200 to 400%, then you need to declare two columns of information—one for the serving size and one for the whole container.”

Proposed nutrition labels more effective than current labels: survey

Consumers find proposed labels easier to read in less time.

How much do consumers use (and understand) nutrition labels?

New research from the NPD Group is questioning how many US consumers even routinely check nutrition labels anymore.

 FDA’s proposed nutrition label changes emphasize calories, serving sizes

If approved, the new labels would place a bigger emphasis on total calories and update serving sizes, while also drawing attention to added sugars and nutrients such as Vitamin D and potassium.

CRN, NPA submit comments on FDA’s proposed changes to food, supplement labels

Both the Council for Responsible Nutrition and the Natural Products Association have submitted a comments on FDA’s proposed revisions for food and dietary supplement labels.

The FDA’s next step is to deal with the comments and issue final rules.  By when?

Eventually.  Stay tuned.

August 1 is the deadline for filing comments on FDA’s food label proposals.

Two were released yesterday, one for and one against.

The Union of Concerned Scientists (UCS) organized a statement in support of listing added sugars signed by 280 scientists, physicians, and public health officials (including me).

The press release says:

In a letter submitted as a public comment for the agency’s first label update since 1994, the signatories point out that sugar overconsumption contributes to diabetes, cardiovascular disease and other ailments….Many food and beverage manufacturers add excessive amounts of sugar to their products, including those that they market as healthy options. In our current food environment, many people are unknowingly and unavoidably consuming excess sugar. Given our soaring rates of chronic diseases and the link between sugar and these diseases, citizens have a right to know how much sugar has been added to their foods.

People who signed the letter include many from Healthy Food Action, a national network of health professionals founded by Dr. David Wallinga.  I am a co-author of the statement with UCS staff and Dr. Robert Lustig.

In contrast, the American Society for Nutrition (ASN), an organization of nutrition scientists to which I belong, produced a strong statement against labeling added sugars.

ASN also has concerns that the inclusion of added sugars on the label may divert attention away from total calories and other important contributors to weight gain. The inclusion of added sugars on the label may confuse consumers and create the perception that naturally occurring sugars are somehow more beneficial because they are “natural” and do not have health effects similar to added sugars…There is no supporting evidence that indicates that the inclusion of added sugars on the food label will translate into the American public reducing caloric intake from added or total sugars or total energy intake…it is important to consider potential unintended consequences of  reformulation as well. When sugar is removed from a solid food product…The replacement is often fat and/or starch which could lead to a product with higher calories per serving. ASN encourages FDA to carefully consider potential adverse consequences of this proposed determination, including gaining input from food scientists…An investment in consumer education… is likely to be most productive for consumer understanding relative to added sugars, and would assure that consumers do not experience increased confusion, which they may encounter if added sugars are declared on the Nutrition Facts label.

These comments, which read as though written by sugar trade association groups, were signed by the president of ASN.  Although the statement letter gives no indication of the process by which these comments were developed, I’m told it was prepared by ASN’s public policy committee.

If so, it would help to know whether members of the committee have financial ties to the sugar industry or to food companies that use sugar in their products.

I wonder how much of the ASN membership agrees with this position on Added Sugars.   I certainly don’t.

 

The FDA is taking comments on its proposals to revamp the food label through August 1, 2014 (instructions are at bottom of post).

I’ve already filed comments on Added Sugars and on whether Vitamin D should be added to food labels.

And I just filed further comments on the FDA’s proposals for the Nutrition and Supplement Facts Labels.  If you would like to read what I said, click here.

I’ve also filed comments on the FDA’s Serving Size proposals.

These proposals are highly technical and tough to slog through, so I tried to deal with the big picture.

July 27, 2014

TO:                  FDA

FROM:           Marion Nestle, Professor of Nutrition, Food Studies and Public Health, New York University

RE:                  Comments: Serving size proposals, Docket No. FDA-2004-N-0258

In addressing the question of how to change serving size designations on food labels, FDA is faced with an impossible dilemma .  Serving sizes, which are supposed to be based on amounts typically consumed from packaged products, are invariably perceived as recommendations for dietary intake.

To comment on each of the bold-face, italicized points:

• Typically consumed:  This information derives from dietary intake surveys which invariably underestimate actual intake, often by 30% to 40%.

• Packaged foods: Food labels only appear on packaged foods.  RACC amounts on packaged foods are often much lower than amounts served in restaurants or fast-food places (pizza is an obvious example).  It is unclear whether amounts reported as consumed are from packages (with Nutrition Facts labels) or are from restaurants or fast-food places where portion sizes can be much higher than those for foods in packages.

• Recommendation:  Substantial anecdotal information suggests that people view labeled serving sizes as what they should be eating.  They view the serving sizes as meaningless compared to the portion sizes of foods they are accustomed to eating.

What is well established is that overall calorie intake has increased since RACCs were established in 1993 and marketplace portion sizes have also increased.

Therefore, any increase in RACC runs the risk of being interpreted as a validation of current portion sizes and as a recommendation to eat more.

On the other hand, larger portions have more calories.  These must appear on the label.

To address this dilemma, FDA should:

• Make dual-column labeling mandatory for all food and beverage packages likely to be consumed in one sitting.
• Require total calories in the package to be displayed on the front of the package.
• Include a footnote explaining that the serving size is not meant as a recommendation

INSTRUCTIONS FOR FILING COMMENTS

The FDA provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

The FDA is taking comments on label proposals until August 1 (see info at end of post).  Here’s mine on voluntary vitamin D labeling.

July 17, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Proposed revision to Nutrition Facts Panel: VITAMIN D

This is to argue against permitting food companies to voluntarily label added “Vitamin” D on the Nutrition Facts panel.  Doing so will not promote—and may possibly harm–public health.

Rationale

• “Vitamin” D is not a vitamin; it is a hormone synthesized by the action of sunlight on skin.  For this reason alone, it does not belong on the food label.
• Vitamin D fortification must be understood as a form of hormone replacement therapy.   As such, it raises questions about efficacy, dose, and side effects that should be asked about all such therapies.
• Fortification and supplementation provide hormone Vitamin D by the oral route.  This is not physiological.  Active vitamin D is synthesized in the body through a series of reactions that begin with the action of sunlight on skin.  Sunlight on skin produces ample Vitamin D, is regulated to promote synthesis as needed and avoid toxicity, and may lead to synthesis of other useful biological components; the unphysiologic oral route does not produce the same benefits.[i]
• As a hormone, Vitamin D is found naturally in very few foods (e.g., fish); in them, it is present in small amounts.  It is present in most foods as a result of fortification.
• Permitting Vitamin D to be listed on food labels will encourage fortification, undoubtedly of foods that would not otherwise necessarily be recommended.  To cite just one example: Yum Bunny Caramel Milk Spread fortified with vitamin D at 10% of the DV.  This product is half sugars by weight, marketed as “a good source of calcium and vitamin D,” and clearly aimed at children. See: http://www.yumbunny.com/about-us.   Whether such products should be considered “good sources” also deserves scrutiny.
• The U.S. Preventive Services Task Force concludes that evidence is insufficient to determine how Vitamin D supplementation (and, therefore, fortification) affects fracture incidence.[ii]^,[iii],[iv] 
• Data from the Women’s Health Initiative also are consistent with largely inconclusive findings about hormone Vitamin D supplements and bone health.[v]
• The Institute of Medicine (IOM) does not consider deficiency of Vitamin D to be a serious problem in the United States, except among certain population groups.  Instead, because of widespread fortification and supplementation, it is concerned about the possibility of adverse consequences from overconsumption through supplementation or fortification.[vi]
• Many scientific debates about hormone Vitamin D are as yet unresolved.[vii]^,[viii]  
• The lack of compelling research has permitted Vitamin D to become “trendy.”  It is advertised on boxes of fortified cereals, has its own pro-supplement advocacy group, and generates millions in annual supplement sales.[ix]

In the absence of stronger evidence for benefit from fortification, and some evidence for possible adverse consequences, the FDA should not contribute to further commercialization of this misnamed hormone by permitting it to be listed on food labels.

References

[i] Wacker M, Holick MF.  Sunlight and Vitamin D: A global perspective for health. Dermato-Endocrinology 2013;5(1):51–108.

[ii] Cranney A, Horsley T, O’Donnell S, Weiler H, Puil L, Ooi D, et al.  Effectiveness and safety of vitamin D in relation to bone health. Evidence Report/Technology Assessment No. 158. Rockville, MD: Agency for Healthcare Research and Quality. 2007.  http://www.ncbi.nlm.nih.gov/books/NBK38410. Accessed February 5, 2013.

[iii] Chung M, Balk EM, Brendel M, Ip S, Lau J, Lee J, et al  Vitamin D and calcium: a systematic review of health outcomes. Evidence Report/Technology Assessment No. 183. Rockville, MD: Agency for Healthcare Research and Quality. 2009.  http://www.ncbi.nlm.nih.gov/books/NBK32603/. Accessed February 5, 2013.

[iv] Chung M, Lee J, Terasawa T, Lau J, Trikalinos T. Vitamin D with or without calcium supplementation for prevention of cancer and fractures: an updated meta-analysis for the U.S. Preventive Services Task Force. Ann Intern Med. 2011;155(12):827-38.

[v] Prentice RL, Pettinger MB, Jackson RD, Wactawski-Wende J, LaCroix AZ, Anderson GL, et al.  Health risks and benefits from calcium and vitamin D supplementation: Women’s Health Initiative clinical trial and cohort study.  Osteoporosis Int.  2013;24(2):567-580.

[vi] Institute of Medicine.  Dietary Reference Intakes: Calcium, Vitamin D.  Washington, DC: National Academies Press, 2011.

[vii] Rosen, Clifford J,  Abrams, Steven A,  Aloia John F. et al.  IOM Committee members respond to endocrine society vitamin D guideline. J Clin Endocrinol Metab. 2012;97:1146-1152.

[viii] Holick, Michael F,  Brinkley Neil C, Heike, A et al  Guidelines for preventing and treating vitamin D deficiency and insufficiency revisited.  J Clin Endocrinol Metab. 2012;97:1153-1158.

[ix] Much growth in vitamin sales driven by vitamin D.  Nutr Business J. 2009;14(6/7):5.

Here’s how to file comments:

The proposed revisions are to:

• Nutrition and Supplement Facts Labels
• Serving Sizes 

The FDA makes it very easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist

File comments here

• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

The FDA is taking comments on its proposals to revamp the food label until August 1, 2014.

It has two sets of proposed changes:

• Nutrition and Supplement Facts Labels
• Serving Sizes

Here is the first of my comments on several food label items.  Feel free to copy, edit, or file your own (see directions below).

July 16, 2014

TO:  FDA

FROM:  Marion Nestle, Professor, New York University

RE:  Nutrition Facts panel: ADDED SUGARS

1.  Retain the line for Sugars but call it Total Sugars

2.  Add a line for Added Sugars

Rationale:

• Excessive intake of dietary sugars is well established to raise the risk of obesity and type-2 diabetes.[i]
• Americans on average twice as much as is generally recommended.[ii]
• The amount typically consumed comes close to the upper limit recommended by the Institute of Medicine on the basis of increased risk of nutrient deficiencies.[iii]
• Sugars intrinsic to foods are accompanied by nutrients; added sugars are not.
• Although there is no biochemical difference between intrinsic and added sugars, food and beverage companies know exactly how much sugar they add as part of the recipes for their products.
• Listing the amount of added sugars on food labels would inform consumers about how much sugars are added to the foods they buy.
• Randomized, controlled clinical trials to test the hypothesis that added sugars increase disease risk would violate ethical standards and, therefore, are impossible to conduct.

3.  Establish a Daily Reference Value for Added Sugars of 10% of total calories

Rationale:

• Since the 1977 Dietary Goals, health officials have consistently recommended an upper limit of 10 percent of calories from added sugars.[iv]
• The 1992 USDA Food Guide Pyramid suggested an upper limit of 6, 12, and 18 teaspoons of sugars, respectively, for daily diets of 1,600, 2,200, and 2,800 calories, respectively.  This works out to 7, 10, and 13 percent of calorie intake, respectively, for an average of 10 percent.[v]
• By 1992, health officials in several European countries had recommended much the same.[vi]
• The Institute of Medicine’s 2002 upper safety limit of 25% of calories was based on risk for nutrient deficiencies, not obesity and chronic disease.[vii]
• In 2009, the American Heart Association recommended that women consume no more than 100 calories per day from added sugars (25 grams), and men no more than 150 calories per day (38 grams).  These come to 5 percent and 7.5 percent, respectively, of a 2000-calorie daily diet.[viii]
• The 2010 Dietary Guidelines for Americans state that no more than 5 to 15 percent of calories should come from a combination of solid fats and added sugars.  This implies that added sugars should be less than 10% of calories.^[ix]
• Dr. Robert Lustig says that a “dose” of added sugars up to 50 grams a day poses little risk for metabolic or chronic disease.  This amounts to 200 sugar calories and 10% of a 2,000-calorie daily diet (he says twice that much, the amount commonly consumed by Americans, is toxic.[x]
• The World Health Organization in 2014 said that added sugars should make up less than 10 percent of total calories per day, and less than 5 percent would be even better,[xi] based on two research reviews, one on sugars and obesity[xii]  and one on sugars and tooth decay.[xiii]
• Added sugars as 10% of calories represents about half the amounts currently consumed and comes close to consensus.

References

[i] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohttp://steinhardt.nyu.edu/nutrition/hort studies. BMJ 2012;345:e7492.  doi: 10.1136/bmj.e7492.

[ii] USDA.  Loss-adjusted food availability documentation.  March 11, 2014.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/loss-adjusted-food-availability-documentation.aspx#.UzlzcfldU6w.   USDA.  Food availability documentation: added sugar and sweeteners.  http://www.ers.usda.gov/data-products/food-availability-(per-capita)-data-system/food-availability-documentation.aspx#sugar.   The tables used to construct figure 3D are at: Refined Sugar, Corn Syrup, Other Sweeteners.

[iii] Institute of Medicine (IOM) of the National Academies. “Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fat, Fatty Acids, Cholesterol, Protein, and Amino Acids (Macronutrients), Chapter 6: Dietary Carbohydrates: Sugars and Starches”, Washington, DC: National Academies Press; 2002.

[iv] U.S. Senate Committee on Nutrition and Human Needs.  Dietary Goals for the United States, December 1977.

[v] USDA.  Food Guide Pyramid, 1992.

[vi] Cannon G:  Food and Health: The Experts Agree.  London:  Consumers’ Association, 1992.

[vii] USDA.  Is intake of added sugars associated with diet quality?  Nutrition Insights, Insight 21, October 2000.

[viii] Johnson RK, Appel LJ, Brands M, et al.  Dietary sugars intake and cardiovascular health: a scientific statement from the American Heart Association.  Circulation. 2009;120(11):1011-1120.  doi: 10.1161/CirculationAHA.109.192627.

[ix] USDA and USDHHS.  Dietary guidelines for Americans, 2010.  http://www.cnpp.usda.gov/dgas2010-policydocument.htm.

[x] Lustig RH.  Fat Chance: Beating the Odds Against Sugar, Processed Food, Obesity, and Disease.  Hudson Street Press, 2012.

[xi] WHO.  Draft guideline: Sugars intake for adults and children, March 2014. http://www.who.int/nutrition/sugars_public_consultation/en/.

[xii] Te Morenga L, Mallard S, Mann J. Dietary sugars and body weight: systematic review and meta-analyses of randomised controlled trials and cohort studies. BMJ 2012;345:e7492 doi: 10.1136/bmj.e7492.

[xiii] Moynihan PJ, Kelly SAM.  Effect on Caries of Restricting Sugars Intake. Systematic Review to Inform WHO Guidelines.  JDR 2014;93:8-18.  doi:10.1177/0022034513508954.

 

The FDA makes it easy to file comments. It provides:

• All necessary information in one place.
• A short guide and checklist
• Nutrition and Supplement Facts Label: Docket FDA-2012-N-1210  Comment here now
• Serving Sizes: Docket FDA-2004-N-0258  Comment here now

ProPolitico writes that the Corn Refiners Association (CRA) and five other industry groups have written the FDA that they intend to fund their own research on the FDA’s proposed changes to the Nutrition Facts label.

The FDA already has a research project underway.

Why would the CRA—the trade association for the makers of high fructose corn syrup—want to bother with an expensive and complicated research project like this?

In an interview, John Bode, CRA president and CEO, told Politico:

The FDA has estimated that changes to the label could cost the industry $2.3 billion, but ‘we suspect that is a very conservative number.

OK.  So one purpose of the research will be to prove that the new food label will cost industry a lot more money than the FDA estimates.

Let me take a guess here and surmise that another purpose will be to prove that listing “added sugars” on food labels “misleads” the public.

This will be industry-funded research.  No matter how well it appears to be done, it is highly likely to produce the answers the CRA wants.

Otherwise, why do it?

If you are a betting person, this one looks like a sure thing.

FDA: finish up those studies and get the results out!

Addition, June 20:  Legal analysts, one a former attorney for CSPI who now works for a law firm representing industry clients, advise against putting “added sugars” on the label.  

 

The FDA is holding a public meeting on June 26 to solicit comments on its proposed rules for Nutrition and Supplement Facts Labels.

The meeting’s purpose is to

• Inform the public of the provisions of the proposed rules and the rulemaking process (including how to submit comments, data, and other information to both dockets)
• Respond to questions about the proposed rules
• Provide an opportunity for interested persons to make oral presentations.

Instructions and information

• Register Online 
• Federal Register Notice
• Fact Sheet on the Proposed Rules

Deadlines for the hearing

• June 12, 2014: Closing date for request to make Oral Comment
• June 12, 2014: Closing date to request special accommodation due to a Disability
• June 20, 2014: Closing date for Registration

The deadline for comments on the proposals has been extended to August 1: Submit either electronic or written comments to FDA’s Division of Dockets Management.

• For the Nutrition Facts Label Proposed Rule, see Docket No. FDA-2012-N-1210.
• For the Serving Size Proposed Rule, see Docket No. FDA-2004-N-0258.

Here’s your chance to weigh in on the proposed label changes.  Don’t miss it!