Last week, I spoke at the FDA public meeting on Proposed Rules on Food Labeling: Nutrition Facts Label and Serving Size. I spoke in support of an added sugars label on those proposed rules, carrying with me the support of 170+ medical, public health, and nutrition experts, 600+ scientists and other technical experts, and an additional 23,000+ citizens.
Given past efforts by sugar interests to obscure the science on sugar and health, I knew to expect some unsubstantiated claims. Sure enough, listening to other stakeholders provide comments, I heard statements in need of correcting. Actors with interests in sugar—including the Sugar Association, the Grocery Manufacturers Association, the American Frozen Foods Institute, and the International Food Information Council—made the inaccurate claims listed below at the FDA public meeting. Notably, trade associations were the ones doing the talking, even though several companies, including General Mills, Kraft, and PepsiCo, had representatives quietly attend the meeting.
Let’s set the record straight on the following five misstatements.
1. Falsely claiming the science doesn’t exist.
Sugar interests—including the Sugar Association and American Frozen Foods Institute—claimed there is no science linking sugar to adverse health impacts. Sugar Association President Andrew Briscoe asserted that “there is no preponderance of evidence” to justify an added sugar label.
Actually, it is quite the contrary. Scientific studies are increasingly showing that sugar overconsumption is a major contributing factor in the rising risks of metabolic syndrome, including diabetes, cardiovascular disease, lipid abnormalities, and hypertension. Several scientific and health authorities—from the World Health Organization to the American Heart Association (AHA) to the Dietary Guidelines for Americans (DGA)—have studied and made recommendations for limiting our sugar consumption. At the FDA public meeting last week, Harvard Medical School and Harvard School of Public Health Professor Frank Hu reiterated this point. “There is compelling evidence,” he stated, that sugar consumption is linked to adverse health effects and Americans’ sugar consumption should be curbed.
2. Red herrings: overlooking the core, established science motivating the FDA
In its comments, the Grocery Manufacturers Association was quick to claim that there is no differing physiological effect for added vs. naturally present sugar and thus, no reason to treat added sugar differently on labels.
This argument is an odd one, because it isn’t relevant to the main point. Whether or not our bodies process added sugar differently, the issue at hand is overconsumption. The average American consumes 20 teaspoons of sugar per day (20!)—this is more than twice the amounts recommended by the WHO, AHA, and DGA. Do they think we are consuming 20 teaspoons of sugars-worth of fruit? Of course not. This overconsumption—and its associated health impacts—are coming from the sugars added to our foods; thus, this is the sugar we need to focus on in our policies, starting with a label.
3. Shifting responsibility to consumers
Speakers, including a representative from the International Food Information Council, questioned whether an added sugar label will change consumers’ behavior (see correction below). And recently, a letter from six trade associations to the FDA made a similar argument in an effort to delay the proposed rules. More generally, shifting responsibility to the consumer to worry about their own “energy balance” and exercise routine is a common strategy by sugar interests (for example, check out the advice of the food industry’s Healthy Weight Commitment Foundation and Coca-Cola’s Beverage Institute for Health and Wellness).
An important point to be made here is that labeling can be effective in ways beyond consumer behavior change. Let’s take the example of trans fats. In 2003, the FDA issued a rule requiring the labeling of trans fats on the Nutrition Facts label, in response to scientific evidence of a trans fat link to heart disease. Following the enactment of this rule, the CDC observed a 58 percent decrease in blood levels of trans-fatty acids in white adults in the U.S. population.
This public health success story was attributed to consumer behavior change, but also to changes in food processing. In response to the new labeling requirement, food manufacturers beginning innovating new ways to formulate foods with minimal or no use of trans fats, rather than be required to disclose trans fat content, a move that manufacturers might have feared could lead to lower sales. Similarly, requiring manufacturers to declare how much sugar they added to foods could motivate the industry to re-think its sugar-heavy products.
4. Claiming unfounded technical challenges
‘There is no way to measure added sugar,’ claimed the Grocery Manufacturers Association.
I know. This argument sounds absurd, and in some ways it is. What is meant by sugar interests here is that there is no established methodology for measuring added sugar content in foods, because this hasn’t been required before. But, you might ask, don’t companies know how much sugar they are putting in foods? Indeed, they should. There are some additional considerations for foods affected by fermentation as this would impact sugar content; however, the FDA is aware of this, and the agency has accounted for this and other factors with built-in flexibility in the rule for these special cases.
5. Speculating paperwork
The Sugar Association president asserted that an added sugar label would require food manufacturers to keep new records on “thousands of products.” “Unprecedented record-keeping,” echoed a representative from OFW Law, which represents food industry actors.
As far as I can tell, this argument is completely fabricated. Unsurprisingly, food manufacturers already must keep records on the content and production process of foods. Requiring added sugar measurement isn’t expected to add to this record-keeping load. In the Q&A session of last week’s public meeting, the FDA validated this when a representative from the Center for Science in the Public Interest asked FDA staff whether an added sugars rule would require food manufacturers to keep additional records. FDA representatives replied as such, “We do not anticipate that the proposed rule on added sugars will require food manufacturers to keep any additional records beyond records they currently keep.” This is in stark contrast to the claims of the above commenters.
Following the science on added sugar
The FDA is taking written public comments on their proposed rules until August 1. Would you like to see the FDA stand up to the above misstatements? Me too. Join us in support of an added sugar declaration on the Nutrition Facts label. After the public comment period ends, we will wait and see if the FDA ultimately follows the science on added sugar and our health.
*CORRECTION, 7/8/14: In the original version of this post, I wrote that the IFIC representative had “claimed there is no evidence” that an added sugar label would change consumers’ behavior. This was an overstatement, and the corrected version more accurately reflects the testimony.