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Save us From FDA’s “Healthy Food”

You may remember from my recent blog about the White House Conference on Hunger, Nutrition and Health, the FDA has issued “proposed rules” for the use of the word “healthy” on food labels.  The proposed rule is a very long complicated document, but the more I read, the more concerned I became.  While the basic concept is valid, there are many loopholes and unintended consequences.  You can read my complete comments to the FDA by clicking below, or keep reading for a summary below.

My biggest concerns about the proposed rules are:

  1.  High Intensity Sweeteners.  The proposed rule puts no restrictions on the use of artificial and “high intensity” sweeteners (aspartame, acesulfame potassium, luo han guo (monk) fruit extract, neotame, saccharin, stevia, sucralose and advantame) in products labeled as “healthy”.  This means that intensely sweet yogurt intended for children with artificial sweetner, could be labeled as “healthy”.  A carbonated soft drink containing a nominal 1/2 cup of apple juice with artificial sweetners, colors and flavors, could be labeled as “healthy”.  There are two dangers here: one is that there is mounting evidence that these sweeteners are potentially harmful, and two, they train our palates to expect (and crave) sweetness all the time.
  2.  “Nutrients to Encourage”.  The proposed rule puts pretty strict limits on the amount of sodium, saturated fat, and added sugar a “healthy” food can contain (this is good!).  However there are no other nutrient requirements.  For example, most Americans do not eat enough fiber and potassium.  But a product high in fiber and potassium is not necessarily “healthy”, even if it meets the limits on sodium, saturated fat and added sugar.  FDA was concerned that setting targets for “nutrients to encourage” would encourage artificial fortification.  But they certainly can (and should) revise the regulations so artificial fortification cannot “count” for “healthy”.  There is so much lacking in the American diet (fiber, potassium, calcium, iron, etc.) that it would be a huge disservice if “healthy” food did not recognize and promote foods with these nutrients.
  3. Oil and High Fat Dressings.  The proposed rule puts no restriction on the amount of vegetable oil a “healthy” food can contain.  As a matter of fact, it promotes putting a “healthy” label on bottles of pure oil and high fat (but not low fat) dressings.  The thinking is to encourage the use of vegetable oils to reduce saturated fat intake.  But they are forgetting that fat has lots of the one thing Americans do NOT need, and that is calories.  One gram of fat has 9 calories, compared to 4 calories per gram for protein or carbohydrate – more than twice.  The average American eats more calories than they need.  We certainly do not need rich, heavy, decadent, high fat, high calorie products labeled as “healthy”!  It is also interesting to note that Americans have already increased their consumption of vegetable oil significantly in the past 25 years but it seems we are less heathy than ever.
  4. Total Calories.  The proposed rule has no limits on how many calories can be in a food labeled “healthy”.  As noted above, even more pressing than the need to eat more fruits and vegetables, is the need for Americans to eat fewer calories.  High calorie foods should not be labeled as “healthy”.
  5. Bottled Water.  The proposed rule promotes labeling pure bottled water as “healthy”.  Water is certainly healthy to drink, but from an environmental standpoint, production and distribution of bottled water is wasteful. Allowing water to be labeled as healthy encourages the unsustainable bottled water industry and potentially takes the emphasis off important efforts to ensure everyone has access to clean, safe, pure tap water at home and in public places.
  6. Examples.  Putting my food scientist hat on, I tried to imagine some foods that would meet the “healthy” regulations as they are written.  I hope you will agree the list is frightening:
    1. Artificially sweetned soft drink with apple juice referenced above.
    2. Sugar and high intensity sweetened yogurt with artificial colors and flavors.
    3. High fat, indulgent frozen dessert made from skim milk and vegetable oils, stabilized and emulsified for creamy texture, sweetened with sugar and stevia.
    4. Potato chips (no reformulation needed).
    5. Whole grain corn tortilla chips (no reformulation needed).
    6. Apple pie with oil-based crust and sweetened with high intensity sweetener.
    7. Indulgent high fat, high calorie, brownie with whole wheat flour, sugar and high intensity sweetener.
    8. High calorie, ooey gooey, frozen macaroni and cheese made from whole wheat or legume pasta, cheese powder, coloring, flavors, vegetable oils, starches, gums and emulsifiers.

The public comment period for these proposed regulations ends December 28, 2022.  Anyone can submit comments.  If you are concerned about what kinds of products can be labeled an advertized as “healthy”, please submit your own comments using the link below. 

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