Docket Management
Docket: 00N-1351 - Food Labeling; Use of the Term "Fresh" for Foods Processed With Alternative Nonthermal Technologies
Comment Number: EC -5

Accepted - Volume 1

Comment Record
Commentor Mrs. Deanne Engstrom Date/Time 2000-07-21 14:19:45
Organization Orange Coast Foods, Inc.
Category Company

Comments for FDA General
1. General Comments RE: Docket # 00N-1351 Regarding the labeling of products that are labeled FRESH, we are submitting the following public comments and ideas. As a 25 year old small business, in the fresh juice industry, we feel that only foods that have not been chemically altered or stabilized in any way should be allowed to sayFRESH on the label. Any method of extending the shelf life of a product, other than putting it into a bacteria free container, alters the chemistry of the product. It is up to this Board of Food and Drug, if for not any other function, to protect the consumer from fraudulent and misleading labeling. Juices and products that say FRESH even though that product has been treated with new technologies or flash pasteurized or any other method of alteration should say EXACTLY WHAT IT IS, Treated Juice, even just JUICE, but not FRESH juice. Juice that has been freshly squeezed but then afterwards treated, frozen, or has had gas added, or any other method of shelf life extension, and either transported or not, should not be allowed to say FRESH because IT ISN'T FRESH any more, it has been treated and therefore altered. Marketing a product, using a new technology that extends the shelf life of a product and leading the public to believe that it is FRESH, alongside a competing product that is truly 'FRESH' and already on the market, is confusing to the consumer. Most people tend to believe a label. Also, if treated products are labeled fresh in a competitive fresh market this could put smaller business at an economic disadvantage. Sincerely, Deanne Engstrom ORANGE COAST FOODS, INC.

EC -5