2005N-0120 Agency Information Collection Activities: Proposed Collection; Comment Request;
FDA Comment Number : EC1
Submitter : Dr. Richard Barndt Date & Time: 05/26/2005 02:05:23
Organization : National Starch Food Innovation
Category : Food Industry
Issue Areas/Comments
National Starch has filed on July 8, 2004 a Citizens Petition with the FDA outlining our views on defining total carbohydrate for nutrition labeling purposes. Our petition requests that Dietary Fiber be excluded from Total Carbohydrates on the Nutrition Facts Panel and listed independently as a separate line item. Separating Dietary Fiber from Total Carbohydrates would begin the process of differentiating digestible and glycemic carbohydrates from non-digestible, non-glycemic carbohydrates on the Nutrition Facts Panel.

If this proposal is accepted, we would not need a separate definition for net carbs, as Total Carbohydrates would essentially become digestible or glycemic carbohydrates. Within the United States, there had been no way to differentiate glycemic from non-glycemic carbohydrates on food labels, so marketers created the concept of net carbs. to communicate this information. Consumers are very interested in this information not only for its impact on the potential weight loss control benefits of eating low glycemic foods, but also because they believe it is a healthier way to eat. Consumers may have tried a low carb diet for weight control, but they are still searching for information on the amount of low glycemic carbohydrates for energy management and other potential health benefits.

Current regulations allow the labeling of total carbohydrates, sugars, other carbohydrates, sugar alcohols, dietary fiber, insoluble fiber and soluble fiber. We believe that removing non-glycemic carbohydrates from total carbohydrates would:
Be easier and simpler for consumers to understand than creating an 8th (i.e., 'net carbs') regulatory category for carbohydrates;
Establish consistency between the carbohydrate content and calorie value on the label;
Positive step toward global label harmonization with the Codex Alimentarius and countries such as the European Union and Australia who have defined Carbohydrates to exclude fiber and sugar alcohols.

For these reasons we feel it unnecessary to create a new carbohydrate definition for 'net carbs'. Through our submission we hope the FDA will strongly consider our point of view to redefine 'total carbohydrates' and include this option in the final selection of carbohydrate content claims selected for the experimental consumer study.