By Bill Moore
Once again, the federal government has clearly demonstrated what happens when a bureaucrat has too much time on his or her hands. This time, it is courtesy of the Food and Drug Administration.
In February, the FDA issued a “draft guidance,” inviting comments on “non-binding recommendations” related to labeling on certain food products. The title of this lunacy is “The Declaration of Added Sugars on Honey, Maple Syrup, and Certain Cranberry Products: Guidance for Industry.”
“Lunacy” is a fairly strong term. It should never be used lightly, so why use it regarding this proposed “draft guidance”? Let’s explore it, shall we?
Here is, for lack of a better term, the preamble: “This draft guidance, when finalized, will represent the current thinking of the Food and Drug Administration (FDA or we) on this topic. It does not establish any rights for any person and is not binding on FDA or the public.”
The first question that comes to mind is, “So why bother?”
In the introduction, the FDA is quite clear that the purpose of this “draft guidance” is to “advise food manufacturers of our intent to exercise enforcement discretion related to the use in the Nutrition Facts label of a symbol “†” immediately after the added sugars percent Daily Value information on single ingredient packages and/or containers of pure honey or pure maple syrup and on certain dried cranberry and cranberry juice products that are sweetened with added sugars and that contain total sugars at levels no greater than comparable products with endogenous (inherent) sugars, but no added sugars.”
They go on: “With respect to the labeling of single ingredient packages of pure honey or pure maple syrup, we are taking this action in response to concerns from stakeholders that consumers might misinterpret the added sugars declaration to mean that non-endogenous sweeteners, such as corn syrup or cane sugar, have been added to the pure product.” Huh? Farmers have added a so-called non-endogenous sweetener to pure maple syrup?
The FDA logic is inescapable.
Pure (100%) honey, pure (100%) maple syrup, and certain cranberry products sweetened with added sugars contribute to the Daily Value of added sugars whether added by consumers to foods (e.g., maple syrup poured over pancakes; sugar added to cranberry juice to increase palatability) or consumed in isolation (e.g., a spoonful of honey). [Moreover], if these products are not labeled with the amount of added sugars per serving, consumers would not be able to understand the relative significance of these sources of added sugars in the context of a total daily diet.
In essence, nutrition labels on pure maple syrup bottles will state that sugar in the product is “added,” even though producers do not use additional sweeteners.
We all need protections from the things that can cause us harm. Sometimes we need the nanny-state guardians to warn us about things like freshly poured coffee in a cup being “hot.” So, it makes absolute sense the FDA is issuing a non-binding “Draft Guidance” requiring maple syrup farmers to label their products with the added sugar notation. The FDA is simply exercising “enforcement discretion for such products to use a “†” symbol immediately following the added sugars percent Daily Value.”
I’m not a maple syrup farmer. However, in the brief time that I have been here, I have met several. I’m pretty sure that they are not using “added sugar” to enhance the flavor of their product. The word “pure” generally means that is what the product is. Ingredient labels are pretty clear that the ingredient in “Vermont Pure Maple Syrup” is just what it purports to be.
Join me in sending a message to the FDA. The “Draft Guidance” should more appropriately be termed “Daft Guidance.” You can send your thoughts online to https://www.regulations.gov, using docket number FDA-2018-D-0075. Written comments can be submitted to: Dockets Management Staff (HFA-305). Food and Drug Administration 5630 Fishers Lane, Room. 1061, Rockville, MD 20852. All comments should be identified with the docket number FDA-2018-D-0075. The comment period ends June 15, 2018.
Bill Moore is president and CEO of the Central Vermont Chamber of Commerce.