2006D-0066

Guidance for Industry and FDA Staff: Whole Grains Label Statements

FDA Comment Number :

EC1

Submitter :

Ms. Susan Ciani

Date & Time:

05/08/2006 01:05:41

Organization :

Ms. Susan Ciani

Category :

Individual Consumer

Issue Areas/Comments

GENERAL

I have two comments.

1. Why are you wasting my money on something that is just guidance? Apparently, manufacturers will be able to continue stating that their products are 'whole wheat' or 'whole grain' when they aren't. So why are you bothering?

2. My family has some particular dietary needs. I try to purchase whole grain items and am dismayed at the reading I have to do just to verify the item does contain only whole grains. For instance, 'whole wheat tortillas' have regular flour in them, too. But that information is in much smaller print than the product's name. I have seen 'whole grain' breads that also contain regular flour.

I also believe the use of the term 'wheat' is misleading to the average consumer. Bread is made from wheat. If it isn't, the manufacturer will tout that anyway - and charge more. I believe manufacturers label bread as 'wheat' to infer whole grain and encourage sales by making the consumer think it is healthier. Even the phrases 'made with' or 'made from' can be misleading with ambiguous meanings.

So, personally, I would like to see regulation where labeling of any grain product (yeast bread, quick bread, cakes, snack foods, tortilla-type products, pastas, noodles, etc.) that requires the use of percentages on the primary label panel if the terms 'whole grain', or the name of any grain is used in the common name of the product. That way, 'Oat Bran Bread' would have to state

'contains X% oat bran'. Or 'Wheat Bread' would have to state 'contains no whole wheat' or even 'contains 100% bleached wheat flour'. That would include rye bread, too.

I spend a lot of time reading labels when I am shopping. Even so, I have purchased items that I later realize aren't what I thought they were. I do not have a problem if manufacturers wish to convey the healthfulness of their products. I just don't think they should not be allowed to take advantage of consumers. I have relatives who buy 'wheat' bread, thinking that it is whole grain. Not every consumer has the time, ability, knowledge or faculties to sort fact from fiction in food labels. Keep it simple, but make it obvious.