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Docket Management Branch July 17, 2003 Page 3 of 4

this argument is unwarranted when applied to sweeteners since HFCS is lower in price than sugar. Soft drink manufacturers have no economic incentive to switch from HFCS to sugar and there is absolutely no evidence that this situation will change in the foreseeable future.

Technological Problems Overstated

In 1993, the “f l e x i b i l i t y ”

soft as a

drink industry cited “technological problems” and the rationale for allowing “and/or” labeling of soft drinks.

need The

for fact

is

that

bottlers today manage larger and more varied inventories, requiring a number of differently labeled packages. Today’s realities demonstrate that the industry has the capability to manage the diversity of label formats required to comply with current ingredient labeling regulations. Hence, current bottling technology has resolved

“t e c h n o 1 o g i . c p r o b l e m s , ” drink industry to comply Passover soft drinks and

while maintaining production “flexibility”

that enables the soft

with FDA’s ingredient labeling Louisiana Pepsi. The soft drink

regulations, as evident in and beverage industries are

proving that the need for “and/or

” labeling is unnecessary.

Contradicts Legal Precedents

The FDA’s legal precedents support continuation of specific ingredient labeling (common or usual name) for nutritive sweeteners, including those used in soft drinks. The FDA has designated that “sugar, in the ingredient statement, should refer 1:o sucrose from sugar cane or sugar beets.” In 1991 the FDA denied the National Soft Drink Association’s 1984 “and/or” labeling petition stating, “Labels on products that do not include the names of specific sweeteners used to fabricate the foods misbrands the products under section 403 (i) of the act.”

Accurate Consumer Information The real issue is consumer deception. Sweeteners are not interchangeable since they differ in the way they metabolize, function and taste. (Attachment 3, Consumer Email)

Gastrointestinal health is one example where consumers may need to know the exact content of their food product. The American Dietetic Association in its 1998 position statement made this distinction between sucrose and HFCS regarding gastrointestinal problem, “Fructose is better absorbed when consumed in sucrose, than in products where the amount of free fructose exceeds the amount of glucose (e.g., in honey, prunes, apples and juice, HFCS, or crystalline fructose). Fructose is primarily absorbed from the gut by facilitated diffusion. Persons vary in their abilities to absorb fructose-some experience symptoms of malabsorbtion with 20- to 50-g load. (A 12-0~ sweetened soda or fruit drink has between 14 and 22 g fructose; 1 c apple juice has 14-g fructose.)” Consumers should be given accurate ingredient information to allow them to make informed decisions when choosing their food products. (1)

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