In formal comments to the Food and Drug Administration, the National Food Processors Association (NFPA) urged the Agency to deny a petition requesting that nutrition labels on foods be revised so that “added sugars” would be declared separately from total sugars. NFPA submitted comments on the added sugars labeling petition to FDA on September 25.

“The petitioner has provided neither sufficient data nor scientific or legal arguments to justify the actions requested,” said Dr. Rhona Applebaum, NFPA’s Executive Vice President for Scientific and Regulatory Affairs. “Specifically, the petitioner has not established a case that it is appropriate to reverse FDA’s 1993 decision, which rejected ‘added sugars’ labeling. Therefore, NFPA strongly urges that FDA take prompt action to deny this petition.”

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The petition was submitted to FDA by the Center for Science in the Public Interest in August, 1999. FDA requested comments on the petition on June 26, 2000.

Dr. Applebaum noted that “It is a well-accepted tenet of public health nutrition that ‘the body cannot tell the difference between naturally occurring and added sugars because they are identical chemically.’ The text quoted is contained in both the 1995 and 2000 editions of the Dietary Guidelines for Americans, the government’s official recommendations to consumers regarding public health nutrition, and a recognized consensus document on the subject. Clearly, there is not public health justification to support the nutrition labeling of added sugars.”

With respect to overweight and obesity, “Declaring the amount of added sugars would provide no additional information to consumers to assist them in maintaining healthy dietary practices, since total sugars already are declared on the nutrition label,” Dr. Applebaum pointed out. “It is well known that caloric consumption that is out of balance with caloric expenditures, regardless of source, is the critical factor in overweight and obesity. Since the nutrition label declaration of the most calorically dense nutrient – dietary fat – did not slow the trend of overweight and obesity, we see no reason to expect that added sugars declarations on the nutrition label will provide information to offset this trend.”

Other points made by NFPA in the Association’s comments to FDA included:

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  • Information about added sugars is not a material fact of the type required to be disclosed to ensure the nutrition label is non-misleading, noting that the material information, on calories per serving and total sugars per serving, is already required to be declared on the nutrition label.
  • There is no established public health need for a Daily Reference Value (DRV) for added sugars. NFPA noted that, in 1990, FDA concluded that there was not a sufficient basis for establishing a DRV for added sugars, and the basis for this decision has not changed in the past decade.
  • Information about the amount of added sugars is not a necessary criterion for general consideration in nutrient content claims or health claims.
  • The definition of “added sugars” proposed by the petitioner is not adequate for the purpose of rulemaking on mandatory nutrition label declaration.
  • Enforcement of any rule to result from this petition could not be supported by science or law. NFPA stated that, contrary to the assertions of the petitioner, currently there are not analytical methods available to accurately differentiate and quantitate the added sugars in foods for nutrition labeling purposes, and pointed out that “The petitioner appears not to be aware of the degree of accuracy needed in analytical methods in order to ensure enforceable nutrition labeling provisions.”
  • The petitioner failed to acknowledge the high costs of such a rule, which would require numerous foods to change their nutrition labels with little, if any, public health benefit.

In conclusion, Dr. Applebaum pointed out that “FDA has taken the uncommon step of publishing a Federal Register notice requesting comments on this petition without also publishing an Advance Notice of Proposed Rulemaking or a Proposed Rule – an action that has drawn a high level of public interest to this issue. Consequently, NFPA recommends that any FDA decision to deny the petition should be published as a notice in the Federal Register, along with some discussion of the Agency’s rationale for its decision. We also recommend that, should the petitioner withdraw the petition without prejudice to a future filing, this fact also should be published as a notice in the Federal Register.”

NFPA is the voice of the $460 billion food processing industry on scientific and public policy issues involving food safety, nutrition, technical and regulatory matters and consumer affairs.

For more information on this issue, contact Timothy Willard, NFPA’s Vice President of Communications, at (202) 637-8060, or visit NFPA’s Website at www.nfpa-food.org.