WASHINGTON — The American Bakers Association, in a letter to the Office of Information and Regulatory Affairs within the Food and Drug Administration, voiced its opposition to planned research that would gauge consumers’ responses to Nutrition Facts labels with various declarations of added sugars.
In its Jan. 30 letter, the A.B.A. said it strongly believes that the F.D.A. should only conduct consumer research experiments around nutrition labeling for those nutrition labeling declarations that the F.D.A. has the authority to require or permit.
“F.D.A. lacks the enforcement tools for a nutrition label declaration for added sugar,” wrote Lee Sanders, senior vice-president of government relations and public affairs at the A.B.A. “Because of this actuality, it is not relevant as to how consumers might respond to a nutrition label declaration of added sugars, as such a feature could not appear on nutrition labels under F.D.A.’s current enforcement authority. F.D.A. should not study labeling elements that the agency cannot require or permit.”
Ms. Sanders noted that while the F.D.A.’s approach to enforcement is based on chemical analysis of a nutrition label declaration, current available chemical analysis cannot differentiate between naturally occurring sugars and added sugars in food. In order to differentiate, the F.D.A. would need access to company formulation records, something the agency does not have for the purpose of nutrition labeling enforcement.
“It should also be recognized that in the baking process 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,” Ms. Sanders said, adding that neither the Dietary Guidelines for Americans 2010 nor the National Education Library literature review has found a casual link between added sugar intakes and obesity.
Ms. Sanders also pointed out that the U.S. delegation to the Codex Alimentarius Commission, Codex Committee of Food Labeling, was one of many delegations that proposed the deletion of added sugars from the list of nutrients “because there were no analytical methods to differentiate between intrinsic and added sugars, which could create difficulties for enforcement.”
The A.B.A. continues to believe a holistic approach to nutrition is the best approach, Ms. Sanders said.
“A declaration for added sugars would … take the emphasis away from total calories,” she said. ‘Labeling that encourages consumers to believe there is a health benefit in monitoring and reducing added sugars content absent of reducing total energy intake serves only to further confuse and undermine consumers’ efforts to improve their health.”