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Docket Management Branch July 17, 2003 Page 4 of 4

Allergens are another example of consumers need for accurate information.

Consumer

concerns about corn Association looking cornstarch added to

allergies are increasing. The number of consumer for alternative sources of powdered sugar without control caking has increased significantly over the

inquiries to the the traditional 3% past few years.

Although HFCS is made up of portions of glucose and portions of fructose, manufacturers also report variable amounts of “higher saccharides,” which mare essentially cornstarch residuals. In, Vol. 56 No. 120 Fed Reg 28604, FDA acknowledged consumer reports of allergic reaction to corn-derived sweeteners. Consumers are entitled to know the exact ingredient in their food product.

The Association believes the product label is the proper context for consumers to evaluate the nutritional quality and ingredients in food products. The use of “and/or” labeling by the soft drink and sweetened beverage industries continues to mislead consumers as to the actual sweetener in these products.

The Association respectfully requests the Food and Drug Administration formally withdraw &ll approval that permits “and/or” labeling for sweeteners in carbonated soft drinks and sweetened, still beverages. A twenty-year track record is proof of the soft drink industry’s longstanding disregard of FDA’s advice, requests and formal warnings. Furthermore, in the past twenty years the soft drink industry has shown by &sole use of HFCS in “and/or” products that the merits of their argument has been predicated on a false premise that has misled the American public and the FDA.

Please do not hesitate to let us know if we can answer any questions or provide further information pertaining to these comments.

Sincerely,

Andrew C. Briscoe, III President and CEO

(1) American Dietetic Association. Use of nutritive and nonnutritive sweeteners -

Position of ADA. Journal of the American Dietetic Association 98(5): 580-587,

1998.

Available

at http://www.eatriaht.com/adapO598.html.

Reaffirmed

2002

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