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 : EC18
Submitter : Ms. Marianne Smith-Edge Date & Time: 04/19/2004 03:04:23
Organization : The American Dietetic Association
Health Care Association
Category :
Issue Areas/Comments
The American Dietetic Association (ADA) represents nearly 70,000 food and nutrition professionals serving the public through the promotion of optimal nutrition, health and well being. ADA appreciates this opportunity to respond to the Food and Drug Administration?s (FDA) advanced notice of proposed rulemaking (ANPRM)--reopening of the comment period--published in the March 1, 2004 Federal Register on trans fatty acids in nutrition labeling. Included with these comments is a copy of previously submitted comments on this topic by ADA in October 2003.

General Comments
The American Dietetic Association has reviewed the Institute of Medicine of the National Academy of Sciences (IOM/NAS) report entitled: ?Dietary Reference Intakes: Guiding Principles for Nutrition Labeling and Fortification,? which was published after the close of the previous ANPRM of July 11, 2003.

The IOM report recommends the use of a combined %DV for saturated and trans fat. As stated in our letter of October 9, 2003, ADA discourages the used of a combined %DV for saturated and trans fats into a common category since that would suggest that trans fat is a form of saturated fat. That is misleading and potentially sets a precedent for a changing interpretation of the entire food label. Furthermore, ADA feels it would not be prudent to pursue either a single or a combined %DV until the food industry has completed its reformulation of products to make them as trans fat free as possible and when accurate trans fat consumption data can be collected.

As previously stated, ADA supports the use of a separate quantitative listing of trans fat on the label of conventional foods and dietary supplements immediately under saturated fats, but without the %DV. Also, ADA strongly advocates testing of Proposed labels with consumers for understanding and interpretation of nutrition messages. Any alternative footnote or label statement warrants further testing to ensure that consumers are not driven toward products that are devoid of trans fat, regardless of the level of saturated fat, total fat or cholesterol.

ADA applauds FDA in its efforts to provide consumers nutrition labels that can clearly help them translate emerging scientific evidence into practical and healthful dietary behaviors. ADA supports an ongoing and intensified program for field-testing consumer education about how to read and use food labels.


Marianne Smith Edge, MS, RD, LD, FADA