Thursday, February 27, 2014

Added Stupidity

This still needs to be confirmed by the FDA, but NPR has released a first look at the updated nutrition facts panel.

In a jaw-dropping example of knee-jerk Food Hysteric capitulation, the FDA has added added sugars as an added row under sugars. Of course, these are proposed changes which may go in effect after a 90 day public comment period.

Expect many comments, especially from the food industry.

Not because the industry has some sort of shame about the amount of sugar in foods, but about the impossibility of validating added sugars for the nutrition facts panel. You see, food companies know what amounts of what ingredients go into a formulation, and therefore, are able to calculate the amounts of sugar added; that's not the problem. The problem is that food companies have to send samples out to be validated every year to make sure the amounts on the NFP are accurate.

How could you possibly test for added sugars, though? You can't. You can only test for total sugars.  This means that if these changes are codified into regulation, the FDA would have no choice but to take each food company's word as to the amount of added sugars in foods.  Sure, they may be able to estimate the amount and check that against the amount of sugars in the formula; the difference would be added sugars. 

But those estimates, like the amount of sugar naturally occurring in concentrated orange juice used in Mnt Dew, could vary by several grams. The FDA, therefore, would have to spot PepsiCo those grams of sugar, giving them the benefit of the doubt. I wonder if the Food Hysterics thought of that when they peddled this nonsense.

They claim added sugars lead to increased fatality from cardiovascular diseases, cited in only one JAMA study.  What's more troubling is that the study only shows a coorelation, not a causation.  The study refers to increases in mortality as sugar intake exceeds 10% of total caloric intake. The study's authors claim they were able to isolate added sugars from total sugars and weed out other conflicting sources of mortality.

Of course, there are a couple problems with this...

First of all, there is only one study, and one study proves nothing.  The second issue is with the data, which was gathered using a survey... I'll give you a moment to sit and think about that....



Yeah. The study's authors depend on surveys from patients who remembered what they ate and how much, so the data is unreliable. Even if the data is accurate, we still have a correlation and not a causation. Scientists would still need to explain how consuming a specific amount of sugar - above what is naturally found in a food - can cause cardiovascular diseases. This is not likely.  The likely explanation is that people eating excessive sugar also were more sedentary, carried higher body fat, et cetera.

The science is not strong and there is little science involved in the proposed changes to the NFP.

There were changes I did like though, like the addition of potassium and vitamin D.  Currently, these are only voluntary, but Americans don't get enough potassium and that may even be a cause of some heart trouble.  They should have also added phosphorous to the list, which is something people with renal diets have to watch very carefully. 

They proposed reducing the amount of sodium, which can be good or bad or pointless, depending on whom you ask and what time of day it is.

I guess the other big thing was the reshuffling of serving sizes, which I have no problem with.

All in all, this may prove to be a cautionary tale in how we need to make changes such as these based upon science and reason, not Food Hysteria.



  1. I'm pretty surprised about the added sugar requirement, but I don't think it's nearly as bad as you purport it to be. GMO labeling would be an example of "Food Hysteria" negatively influencing policy. I feel this is just common sense.

    If you actually dig into the FDA Federal Register notice, page 95 (, they essentially acknowledge that there isn't the "hard science" showing a causation between added sugar consumption and obesity/diabetes/insert health condition here. However, IN THIS CASE I agree with them that there doesn't need to be a "smoking gun" study proving causation to justify including this new information on the label. (Due to the inherent limits of observational studies, I think it would be nearly impossible to prove such a causation exists.)

    People consume too much sugar overall, much of it being sugar added to foods. Other than calories, added sugar provides little to no nutritional benefit. I think many consumers are not aware the extent to which caloric sweeteners are added to make "healthy" products tasty. Prime examples include yogurt and fruit drinks. By seeing the amount of sugar that is added, a consumer may pause and consider a healthier alternative. This new information can only help the consumer.

    I do think it will be tricky to ensure labeling compliance. This is the FDA's issue though, not the industry's. According to the Register notice I posted, the FDA will expect manufacturers to keep "records" of added sugars. I'm not sure what this means, but I'm sure we'll learn more moving forward.

  2. They already are able to watch the amount of sugar through total sugars, making added sugars irrelevant. Too much sugar may well be a problem, but it's sill to try to say that sugar already in the food doesn't count and the sugars that are added is what really matters. The body doesn't work that way.

    As far as record keeping goes, batch sheets are stored in manufacturing facilities and these will indicate how much sugar is added.

  3. No one is making the argument that added sugar is worse than naturally-present sugar from a caloric standpoint. If calories are the only concern, I think everyone is in agreement that total sugar is the more valuable metric. But, they aren’t removing total sugar from the label, so no harm there. I think if people decrease the amount of added sugars they consume, they may consume less sugar overall. This is a good thing.

    Another thought is that you get more overall nutritional "bang for your buck" when consuming naturally-present sugars, because naturally-present sugars often are “packaged” with other essential nutrients. Here's an extreme example: In 100 g cola, there are 38 calories, 9 g total sugar and 9 g added sugar. In 100 g pomegranate, there are 83 calories, 14 g total sugar and 0 g added sugar. Which is the healthier option? I’d say the pomegranate, even though it contains more total sugar. Why? It contains potassium, fiber, a bit of protein, some vitamins/minerals, and lots of phytochemicals. It will take you longer to consume and leave you more satiated, as well.

    Lastly, let’s consider the harm an added sugar label will cause. Certainly, this will cost the industry a bit. They will have to update labels, acquire added sugar values from suppliers, and potentially reformulate products if they wish. Also, sales of products with lots of added sugars may decrease, as consumers seek healthier options. (Industry will recover and innovate, no doubt.) The FDA predicts this will come at a cost of $2 billion to the industry, but with a benefit of $20 billion to the public. Spread out, I don’t think the cost will put anyone out of business. Some of the big companies saw this coming, and already have records of added sugar values for their products. Regardless, after the new NFP proposal is finalized, industry will have 2 years to complete changes. You may argue that mandating added sugar values without a causative link to health problems will open the door to other labelling mandates (e.g. GMO). I think that’s a slippery slope argument. The main difference is that GMO labelling would likely negatively impact the consumer. I can’t think of a scenario where the added sugar label will do such.

    For the record, I think you have a lot of good thoughts on this blog in general, most of which I agree whole-heartedly. Honestly, I've gone back and forth on whether or not I agree with the added sugar mandate, but I think the potential benefits to society outweigh the costs to industry.

    1. It's too bad that the cola mfr can't legally add K & fiber to their formula to give it the health benefits of eating fruit.

      There are a great many foods that have more of a specific nutrient, are more nutrient dense, or less calorically dense than certain other foods. It's not as if people only drink the cola and never have the pomegranite. It's not like the Highlander of food - there can be many more than one. But when we make 'Eat this, not that' style comparisons between foods, we ignore how we actually eat. Only a relatively few people ONLY eat things high in added sugars. It seems we are putting a lot of emphasis on added sugar as the cause of our problems, as if to say that removing added sugars will make fat people go away. It won't.

      Most people eat a variety of foods and most people, regardless of body type, are healthy. Obesity may be considered an epidemic, but it describes a minority of the country.

      This is why I think the science needs to be more solidly behind the decisions out regulatory agencies make in how things are labeled. We probably need to triple the amount of grant money going to nutritional research, so we can run well supervised feeding trials and collect accurate data. We should probably also staff the FDA much better, so CFSAN can do more independent research and verification of label claims. We should probably also regulate dietary supplements in this country, so people don't get a warped sense of the relative safety/harm of the things we eat.

      Sugar appears to be the current villain, but remember just a few years ago the villain was fat. Maybe the harm is negligible, but I think we should be certain we are putting sound science behind our labeling and not dietary fads.


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