Looking at the question of reasonableness, probably most Americans would agree that it would be inappropriate to advertise tobacco to an age group of individuals not yet old enough to responsibly understand the serious risks associated with the activity. While far more debatable, a similar argument could be extended to regulating makers of sweet treats such as cookies, candy, ice cream and soft drinks. But enriched grains are in an entirely different realm. Here we are discussing products with solidly grounded nutritional credentials, products that have formed the foundation of the human diet for millennia.
With ready-to-eat cereals, enriched grain products such as bread are the leading source of micronutrients in the American diet. By requiring that advertised baked foods contain whole grains, the federal government for all practical purposes is placing enriched flour on the list of restricted ingredients to be avoided, with saturated fat, trans fat, added sugars and sodium. What appears to be going on here is that the federal government is saying that advertising to children should only be allowed for healthful foods for which consumption levels are deemed too low. This approach is neither reasonable nor sensible, and the plan should be changed.
As proposed, the baking industry should not comply with the standard. It may be hoped baking will be able to use the proposal to help the public better understand the true healthfulness of its products.