The Sugar Association is disappointed by the Food and Drug Administration’s (FDA) ruling to require an “added sugars” declaration and daily reference value (DRV) on the Nutrition Facts Label (NFL).
The extraordinary contradictions and irregularities, as well as the lack of scientific justification in this rulemaking process are unprecedented for the FDA. We are concerned that the ruling sets a dangerous precedent that is not grounded in science, and could actually deter us from our shared goal of a healthier America.
FDA has openly admitted it deviated from factors traditionally considered for mandatory declaration of nutrients on the NFL (i.e. chronic disease, health-related conditions). Instead, FDA arbitrarily selected from general dietary guidance and science of low evidentiary value to support its proposal for “added sugars” labeling and to set a DRV. FDA also ignored comment from the European Commission inviting them to reconsider their position, citing lack of distinction between total and added sugars. It is a fact that sugars, whether intrinsic or added, break down to glucose, fructose and galactose and the body can’t tell the difference.
In addition, FDA’s statutory requirement for adding a non-statutory nutrient to the NFL is that is the nutrient’s listing is necessary to assist consumers in “maintaining healthy dietary practices.” Yet FDA’s own consumer research shows that the focus on “added sugars” may actually undermine consumer efforts to improve their diets. FDA’s research found that when the more nutritious foods (i.e. lower-calorie, lower-fat, higher-fiber and higher-vitamin) have more added sugars, the percentage of respondents identifying that product as healthier decreases. An important point — and as the marketplace already shows, reduced sugar foods are often higher in fat and calories.
As with the backfire of single-nutrient emphasis on reducing fat in the 1990s, added sugars labeling may undermine consumer efforts to have healthier diets. FDA’s own Obesity Working Group report, “Calories Count,” recommended that labeling should deemphasize individual macronutrients in the Nutrition Facts Panel and emphasize the caloric contribution of a product.
Rehashing the failed policies of the past by focusing on a single nutrient and not calories may once again prove unsuccessful in improving health outcomes and result in consumer confusion, ultimately undermining consumer trust and increasing consumer apathy, something we can ill afford as we search for meaningful solutions to the complex problem of obesity.
The Sugar Association remains confident that if an official Dietary Reference Intake process was undertaken by the National Academy of Science, the science used by FDA to propose “added sugars” labeling and a DRV would not withstand the scrutiny of a quality, impartial evaluation of the full body of scientific evidence.
To view The Sugar Association’s submitted comments regarding “added sugars” labeling, click here: http://www.sugar.org/wp-content/uploads/2015/10/Sugar-Association-Supplemental-Proposed-Rule-Comment-FDA-2012-N-12103.pdf