WASHINGTON — Food industry associations in comments recently submitted to the Food and Drug Administration applauded the agency’s intent to provide guidance on whole grain label statements. But they asserted the F.D.A.’s draft guidance issued in February was too restrictive and if not revised would deprive consumers of valuable indications of how particular foods relate to the recommended consumption of whole grains contained within the Dietary Guidelines for Americans 2005.
The F.D.A.’s draft guidance addressed several issues by asking 11 questions relating to whole grain label statements, providing answers reflecting its current thinking relating to those questions, and requesting public comment on that thinking.
A few issues proved non-controversial with food manufacturer groups, but there was disagreement on some key issues. The F.D.A. asked, "Does the term ‘whole grain’ mean the same as ‘100% whole grain?’ If a product is labeled as ‘whole wheat bagel’ or ‘whole wheat pizza,’ how much whole wheat should it contain?"
In answer to its own question, the agency recommended products like pizza or bagels that are labeled "whole grain" or "whole wheat" should only be labeled as such when the flour ingredient in the crust is made entirely from whole grain flours or whole wheat flour, respectively.
The agency acknowledged it had not defined any claims concerning grain content of foods, but added it established standards of identity for "whole wheat flour" and for "whole wheat bread, rolls and buns" made from such flour. The latter were required to be made only from 100% whole wheat flour. And this rule provided a basis for its thinking on this question.
The Food Products Association, Washington, objected, stating the F.D.A.’s draft guidance is too narrow for products like "whole grain" bagels or pizza. "Such a bagel or pizza could be made with a mixture of whole grain and enriched or refined grains," the F.P.A. said "As long as the product contains more than 50% whole grain in the grain component, F.P.A. believes it is proper and non-misleading for the label to state ‘whole grain.’"
The F.D.A.’s guidance relating to characterizing whole grain content of foods with descriptors such as "good source" and "excellent source" of whole grains also proved particularly contentious.
According to the agency, manufacturers may make factual statements about whole grains on the label of their products, such as "10 grams of whole grains," provided the statements are not false or misleading and do not imply a particular level of the ingredient, i.e. "high" or "excellent source."
The Grocery Manufacturers Association responded the F.D.A.’s final guidance should exclude the statement prohibiting manufacturers from implying a particular level of an ingredient is "high" or "excellent source" of whole grains.
"To the contrary, use of these terms would not be misleading but rather will serve to provide consumers with truthful information that they can use to improve their dietary practices," the F.D.A. said.
The G.M.A. noted products containing less than 100% whole grains still provide meaningful nutritional and health benefits and often satisfy the taste preferences of a larger numbers of consumers.
Judi Adams of the Grain Foods Foundation, in her comments to the F.D.A., agreed and cited scientific research that showed the reduction in the risk of disease from whole grain intake is not significantly affected by the content of an individual food but by the total whole grain amount consumed.
The trade associations also challenged the authority of the F.D.A. to prohibit the use of "good source" and "excellent source" descriptors in relation to whole grains, as its authority with regard to those terms relates only to nutrients, whereas whole grains generally were considered an ingredient. The groups said as long as such descriptors were not misleading or untrue, they should be allowed.
The G.M.A. suggested the F.D.A. might consider itself defining what amounts of whole grains in a food would qualify for use of the descriptors "good source" and "excellent source" of whole grains. For instance, an individual serving of a food containing 8 grams of whole grains (one-sixth the daily recommended amount) could earn the descriptor "good source," and a single serving of a food containing 16 grams of whole grains (one-third the recommended daily intake) could earn the descriptor "excellent source" of whole grains. But whether by non-misleading industry use of the terms, or agreement between government and industry on definitions for the terms, the descriptors should be allowed as they are well understood by consumers and proper use of the descriptors would assist individuals make healthful choices in their diets.