WASHINGTON — The American Bakers Association said it opposes the Food and Drug Administration’s plan to conduct research on how consumers would respond to the listing of “added sugars” on the Nutrition Facts Panel.

The F.D.A. in the May 31 Federal Register said it planned to explore consumer responses to various food label formats, including the listing of added sugars, for the footnote area of the Nutrition Facts Panel.

In comments sent to the F.D.A. on July 30, the A.B.A. said, “A.B.A. believes strongly that F.D.A. should only conduct consumer research experiments around nutrition labeling for those nutrition labeling declarations that F.D.A. lawfully could require or permit. Therefore the proposal does not have practical utility based on the current regulatory framework.”

The A.B.A. said available chemical analysis is unable to differentiate between naturally occurring sugars and added sugars in food. For the F.D.A. to differentiate between naturally occurring sugars and added sugars, it would need to access company formulation records. However, the F.D.A. does not have the authority to access formulation records for the purpose of nutrition labeling enforcement.

The A.B.A. also noted overall sugar levels change from the formulation in raw dough or batter to the level in the final product because of the fermentation process usage of sugar and additional chemical reactions in the baking process.

Other points made in the A.B.A. comments included:

• The body does not distinguish between added sugars and naturally occurring sugars, according to the Nutrition Labeling and Education Act;
• The U.S. delegation to the Codex Alimentarius Commission, Codex Committee on Food Labelling proposed the deletion of added sugars from the list of nutrients because there were no analytical methods to differentiate between intrinsic and added sugars;
• The European Food Safety Authority in 2010 concluded, “Available data do not allow the setting of an UL (upper level) for total or added sugars, neither an AI (adequate intake) nor a recommended intake range;
• The emphasis on individual micronutrient content over the caloric content is at odds with the principles expressed in the F.D.A. obesity working group’s “Calories Count” report and recommendations.