Food Thoughts

Closer to “Added” Sugars Labeling

by Bill Layden and Sarah Levy

TWOFI Sugar Sept 2015

On July 27, 2015, the US Food and Drug Administration (FDA) issued a supplement to its March 2014 proposed rule to update the Nutrition Facts Label (NFL). In addition to requiring the declaration of added sugars, the supplement also proposes to, for the first time, establish a Daily Reference Value of 10 percent of total energy from added sugars and require the declaration of a percent Daily Value (DV) for added sugars on the label. FDA took this action following the release of the 2015 Dietary Guidelines Advisory Committee (DGAC 2015) Scientific Report, and in large part because of this report’s recommendations. Results from FDA’s recently completed consumer research study also informed the supplemental proposal.

Added Sugars Regulation

By law, the US federal government updates the Dietary Guidelines for Americans (DGA) every 5 years and relies on an expert advisory panel to review the science on diet and disease prevention and health promotion. In February 2015, the DGAC 2015 issued its scientific report after two years of deliberation and review. Among its many findings, the Committee concluded that strong evidence exists to show that intake of added sugars is associated with excess body weight in children and adults; strong evidence also shows that higher consumption of added sugars, especially sugar-sweetened beverages, increases the risk of type 2 diabetes among adults; and that moderate evidence from prospective cohort studies shows a consistent association between added sugars intake and cardiovascular disease risk in adults. As a result of these findings, the DGAC 2015 recommended limiting added sugars intakes to a maximum of 10% of total daily calories. Although added sugars intakes have been decreasing in the US across all life stage groups, mean intake is 268 calories, or 13% of total calories per day. For children ages 9 and older, adolescents, and young adults, added sugars comprise 15%- 17% of total calories per day, according to the DGAC 2015 report. The DGAC 2015 specifically recommended labeling added sugars and including a percent DV on the NFL. The DGAC 2015 also evaluated the relationship between low-calorie sweetener consumption and health outcomes. While the report recognized that substituting low calorie sweeteners for sugar can help achieve short-term weight loss, the Committee found that longterm effects on consumption are uncertain. Therefore, the DGAC 2015 concluded that these sweeteners should not be recommended for use as a primary replacement or substitute for added sugars in foods and beverages.

Controversial Advice

It should be noted that the DGAC 2015 report has been particularly controversial in the US, because of concerns that the Committee exceeded its scope of responsibility by reviewing issues around sustainability, making policy recommendations, relying too heavily on third-party scientific reviews, and inconsistently applying standards of evidence in its evidence-based reviews. The Departments of Health and Human Services (DHHS) and the US Department of Agriculture (USDA), which jointly administer the DGA process, have received over 30,000 public comments on the DGAC 2015 Scientific Report — an unprecedented number. The Departments are expected to publish the final DGA policy document by the end of 2015.

Influencing Understanding

In its recent supplemental proposed rule, FDA shared the results of its consumer research on how added sugars labeling and alternative footnote statements may influence consumer understanding. According to FDA, when both total and added sugars labeling were available, the majority of consumers could identify the products with less added sugars. However, FDA acknowledges that it did not test the inclusion of a percent Daily Value and that a number of consumers were confused about the distinction between total and added sugars. FDA ultimately concluded, however, that added sugars labeling would be useful to consumers. A separate consumer research study, conducted by the International Food Information Council (IFIC) Foundation, demonstrated that consumers struggled to identify the amount of sugars in food products when both total sugars and added sugars were included on the NFL. Added sugars labeling proved to be misleading and the resulting misperception influenced purchase intent. The current version of the NFL led to the highest rates of consumer understanding in this study.

Unnecessary Distinction?

The lack of data to suggest that added sugars labeling will improve consumers’ ability to make healthier food choices is one reason why added sugars labeling is a controversial issue. Opponents also argue that there is no physiological or metabolic difference between sugars added during manufacturing and sugars naturally occurring in foods, making their distinction on the NFL unnecessary and misleading. Furthermore, critics contend that inadequate scientific evidence exists to support a direct relationship between added sugars and obesity or heart disease, and many question the effectiveness of a single-ingredient or single-nutrient focus and approach to improving health. While many US consensus reports agree with these points, proponents of added sugars labeling assert that higher intakes of added sugars lead to greater consumption of total calories and the displacement of other nutrient-dense foods and beverages in the diet. As is the case today for a number of controversial nutrition topics, the debate often boils down to whether existing science and potential public health benefits justify policy and regulatory action.

The Reformulation Impact

Added sugars labeling is even proving to be divisive within the food and beverage industry. While many companies continue to oppose the recent actions taken by FDA and the DGAC 2015, others are taking a supportive position, maintaining that added sugars labeling is a matter of providing consumers with the information they want and need to help them make informed purchasing and dietary decisions. We are beginning to see these effects in the marketplace, with companies reformulating existing products to contain less sugars and creating new product line and portfolio extensions to address added sugars concerns. Added sugars will likely continue to feature prominently in nutrition and public health policy and regulatory decision making over the next several years. The FDA NFL final rules are expected to be published by mid- 2016, and later this year DHHS and USDA will decide whether or not to adopt the DGAC 2015 recommendations into the final policy document. If the 2015 DGA ultimately recommend labeling, a percent DV and a daily intake limit for added sugars, US dietary guidance and federal nutrition assistance programs such as the Supplemental Nutrition Assistance Program (SNAP), school meals programs, and the Special Supplemental Nutrition Program for Women, Infants and Children (WIC), will be expected to follow suit, resulting in potentially dramatic changes to the US food and nutrition landscape.

Bill Layden is a Partner and Sarah Levy, MPH, RD is Vice President at FoodMinds, LLC. 

This article appeared in The World of Food Ingredients, September 2015 issue.