2003N-0076 - Food Labeling: Trans Fatty Acids in Nutrition Labeling; Consumer Research to Consider Nutrient content and Health Claims and Possible Footnote or Disclosure Statements; Reopening of the Comment Period
FDA Comment Number : EC9
Submitter : Mr. Steve Cockram Date & Time: 03/22/2004 03:03:19
Organization : Northland Cranberries, Inc.
Category : Food Industry
Issue Areas/Comments
March 15, 2004

Via Web (www.fda.gov/dockets/ecomments)

Dockets Management Branch (HFA-305)
Food and Drug Administration
5630 Fishers Lane, Room 1061
Rockville MD 20852

Re: Docket No 2003N-0076
Comments to trans Fat in Nutritional Labeling ANPR

Dear Dockets Custodian:

This letter represents the comments of Northland Cranberries, Inc. (?Northland?) in response to FDA on the advanced notice of proposed rulemaking for the Food Labeling: Trans Fatty Acids in Nutrition Labeling.

Northland is a vertically integrated grower, handler, processor and marketer of cranberries and value-added cranberry products. Northland sells its own brand of 100% juice cranberry blends and fresh cranberries, as well as Seneca brand juice products, through retail supermarkets and other distribution channels nationwide. Northland markets to industrial customers who manufacture juice products. We hope that food products with zero fat will not be burdened with an additional mandatory trans fat disclosure statement in the Nutrition Facts panel.

All of our juice products contain zero fat, trans or otherwise. Northland has been proactive in complying with all nutritional labeling regulations. Since the trans fat rules were published in July 9, 2003, we have invested in new labels to include trans fat in the Nutrition Facts. We believe that zero fat food products do not need any additional disclosure statements or nutritional footnotes about trans fats. While a company may want to highlight that their product contains no trans fat, FDA has long required products inherently low in ?bad? nutrients (fat, sugar, sodium, etc) to qualify any content claim by stating that the whole class of foods has few of those nutrients. Following that logic for a fat free food, any proposed trans fat disclosure statement would also need a qualifier to the disclosure. A disclosure will add unnecessary language to the nutritional information panel, where a simple zero or ?Not a Significant Source of?? statement will suffice to educate the consumer.

Northland intends to fully comply with any final nutritional regulations. We trust we will not have to continue to invest in additional new labels for a food product that does not contribute trans fat to the diet. If FDA believes a disclosure statement is needed, then it should only be on those specific products that contain trans fats. Thank you for you consideration of our comments. Please feel free to contact me if you have any questions or we can provide additional information.


Steve Cockram
Director of Technical Services
Northland Cranberries, Inc.
2930 Industrial St
Wisconsin Rapids WI 54495

cc: Ricke Kress
Ken Iwinski