{"id":21496,"date":"2023-07-11T10:00:50","date_gmt":"2023-07-11T14:00:50","guid":{"rendered":"https:\/\/www.vrg.org\/blog\/?p=21496"},"modified":"2023-06-19T10:20:17","modified_gmt":"2023-06-19T14:20:17","slug":"the-vegetarian-resource-group-testimony-concerning-dietary-guidance-statements-on-food-labels-submitted-to-u-s-food-and-drug-administration-fda","status":"publish","type":"post","link":"https:\/\/www.vrg.org\/blog\/2023\/07\/11\/the-vegetarian-resource-group-testimony-concerning-dietary-guidance-statements-on-food-labels-submitted-to-u-s-food-and-drug-administration-fda\/","title":{"rendered":"The Vegetarian Resource Group Testimony Concerning Dietary Guidance Statements on Food Labels Submitted to U.S. Food and Drug Administration (FDA)"},"content":{"rendered":"

\"\"<\/a><\/p>\n

We are generally in agreement with the concept that quick signals on the front of packages help consumers better understand nutrition information. The proposed guidance for industry is generally understandable and useful. We agree that nut or seed products that do not exceed the recommended levels for sodium and added sugars should be allowed to include a Dietary Guidance Statement despite exceeding the recommended saturated fat level. As discussed in the proposed guidance, nuts and seeds are considered nutrient dense foods, have a fat profile of predominantly monounsaturated and polyunsaturated fats, and consumption of these foods is associated with beneficial health outcomes.<\/p>\n

We are pleased to see that the proposed guidance supports \u201cthe use of Dietary Guidance Statements on all plant-based milk and yogurt alternatives \u2013 not just soy based alternatives (page 22). This inclusion of additional plant-based milk and yogurt alternatives allows for flexibility and for the inclusion of newly developed products rather than limiting use of Dietary Guidance Statements to only products that are based on soy. We agree that plant-based milks and yogurt should meet specific recommendations for overall nutrient content but encourage the FDA to review and consider revision of USDA\u2019s FNS fluid milk substitutes nutrient criteria. For example, these criteria call for plant-based milks to contain 8 grams of protein per 8 ounce serving. Protein is rarely deficient in diets of Americans so a relaxation of this requirement, perhaps to 4 grams or 6 grams of protein per 8 ounce serving, is unlikely to have negative health consequences. This relaxation could allow greater variety in those fortified non-dairy products that could include Dietary Guidance Statements.<\/p>\n

We are concerned that in situations when a food is recommended by a consensus report as part of a
\nnutritious dietary pattern and the food has a nutrient profile that exceeds the recommended nutrient levels in this guidance, the product could bear both a Dietary Guidance Statement and a disclosure
\nstatement about the recommended nutrient level(s) it exceeds (page 30). This results in a potentially
\nconfusing mixed message that does not achieve the goal of helping consumers, especially those with
\nlower nutrition or health literacy, to better understand nutrition information. For example, in Figure 4, our initial impression was that the message was saying that yogurt is a good way to obtain added sugars.<\/p>\n

At a minimum, this mixed messaging should be tested with consumers to determine what the
\nconsumers perceive about a statement saying, \u201cchoose this food\u201d and \u201cthis food is high in added
\nsugars\/saturated fat\/sodium.\u201d If further investigation suggests consumer confusion, products that
\nexceed recommended nutrient levels from added sugar, sodium, or saturated fat (with the exception of
\nnut and seed products), should not be able to bear a Dietary Guidance Statement under any
\ncircumstances.<\/p>\n

Thank you for the opportunity to comment on this issue.<\/p>\n","protected":false},"excerpt":{"rendered":"

We are generally in agreement with the concept that quick signals on the front of packages help consumers better understand nutrition information. The proposed guidance for industry is generally understandable and useful. We agree that nut or seed products that do not exceed the recommended levels for sodium and added sugars should be allowed to […]<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1],"tags":[],"class_list":["post-21496","post","type-post","status-publish","format-standard","hentry","category-uncategorized"],"_links":{"self":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/21496","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/comments?post=21496"}],"version-history":[{"count":1,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/21496\/revisions"}],"predecessor-version":[{"id":21498,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/posts\/21496\/revisions\/21498"}],"wp:attachment":[{"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/media?parent=21496"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/categories?post=21496"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.vrg.org\/blog\/wp-json\/wp\/v2\/tags?post=21496"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}