Food Labeling: Revision of the Nutrition and Supplement Facts Labels; Issued July 2015 (Docket No. FDA-2012-N-1210)

Dear Sir or Madam:
The Research Evaluation Panel of the American College of Nutrition (ACN) appreciates the opportunity to provide comments on the Food and Drug Administration’s (FDA) proposed food labeling rules, which would establish a Dietary Reference Value (DRV) for added sugars as well as require that the Percent of Daily Value (DV) for added sugars be displayed on the Nutrition and Supplement Facts labels.

The mission of the ACN, founded in 1959, is to advance nutrition science to prevent and treat disease. We stimulate nutrition research and publication, elevate nutrition knowledge among clinicians and researchers and provide practical guidance on clinical nutrition. We accept no funding from for-profit corporations, reinforcing our commitment to advancing the science without compromise. Our flagship programs are our prestigious Journal of the American College of Nutrition, our Annual Conference in its 56th year, and our “Fellow of the American College of Nutrition” designation, for elite nutrition researchers and clinicians.

The topic of added sugars is key to health. Thus, our comments as the ACN's Research Panel are designed to provide scientific information we believe should be incorporated into the final rule.

Labeling for Added Sugars is Essential and Education is Required
We support the rule to label added sugars and recommend that the Nutrition Facts Label be developed such that added sugar labeling can be clearly interpreted by consumers, clinicians, and researchers. Furthermore, we call upon the FDA to provide education on the differences in the composition and metabolism of the various types of added sugars to health professionals and consumers.

Added sugars differ widely in their composition and metabolic effects. For example, high-fructose corn syrup (HFCS), a refined added sugar with documented detrimental metabolic effects, cannot be equated with, for example, honey or molasses, which may exhibit certain health benefits i ii iii iv. Moreover, highly-processed sweeteners like HFCS have been shown to contain contaminants as a result of manufacturing processes v. We believe that it is crucial for the consumer to understand the differential health impacts of various types of added sugars, and to know that they are not metabolically equivalent. Thus, supplementary education about what “added sugars” means, based on a consistent, federally mandated requirement, would provide clarity for consumers. We encourage the FDA to mount a consumer outreach effort explaining the relationship between added sugars and their health effects.

Further to this point, we propose that a component of this educational initiative address synthetic, non-nutritive sweeteners. We are concerned that added sugar labeling might lead consumers to perceive such sweeteners as superior to added sugars from a health perspective. Such sweeteners share similar detrimental effects to added sugars, in that they have been associated with obesity, type 2 diabetes, metabolic syndrome, and cardiovascular diseasevi, some of which may be mediated through detrimental changes to the gut floravii. In some cases, artificial sweeteners are associated with weight gain possibly due to compensatory overeating triggered by their effects on taste viii.

Added Sugars Are Shown to Increase Risk of Chronic Disease
The Dietary Guidelines for Americans 2010 declared that Americans consume too many calories from added sugars and that consuming added sugars is not considered part of a healthy eating pattern ix. Well-designed systematic reviews, meta-analyses, and clinical studies have also demonstrated that consumption of added sugars through sugar-sweetened beverages and snack foods leads to increased risk for chronic diseases such as cardiovascular disease, metabolic syndrome, and obesity x xi xii xiii xiv xv. Consuming foods and beverages high in added sugars may displace essential, nutrient-dense, whole foods in the diet xvi and thus further increase chronic disease risk. Moreover, the Scientific Report of the 2015 Dietary Guidelines Advisory Committee states: “Higher consumption of sugar-sweetened foods and beverages…was identified as detrimental in almost all conclusion statements with moderate to strong evidence.  xvii

Added Sugars Should Not be Assigned a Daily Recommended Intake Level
Added sugars are not essential to the diet, and should not be assigned a recommended daily intake level. Most types of added sugars supply extra calories but few, if any, essential nutrients. Reducing or eliminating added sugars from the diet lowers caloric intake without compromising nutrient content. Adequate levels of carbohydrate can be obtained from complex starches, vegetables, legumes, whole grains, and naturally-occurring sugars such as those obtained from fruits.

Secondly, intake of added sugars, even at levels lower than those being suggested in this proposed labeling rule (i.e., less than ten percent of energy from calories), has been shown to have pronounced, detrimental health effects xviii. Dose-dependent negative effects of added sugars on cardiovascular and metabolic markers have been found by researchers, and others have identified high triglyceride levels in the bloodxix.

Finally, we believe that added sugars should be viewed similarly to trans fats: that is that they are not essential – and, in fact, detrimental – to health, especially with respect to increasing risk for cardiovascular disease. The approach to trans fat labeling, whereby no recommended level of daily intake is set, has had a beneficial impact on consumption of trans fat xx xxi. A similar approach to labeling added sugars is warranted.

If additional information on this critical public health topic would be helpful, please contact us. Thank you for your consideration of this comment.

American College of Nutrition
Research Evaluation Panel

  • Jeffrey S. Bland, PhD, FACN, CNS 
  • Leo Galland, MD, FACN
  • David Perlmutter, MD, FACN, ABIHM
  • Nicholas V. Perricone, MD, MACN, CNS

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ii Aslan Y, Erduran E, Mocan H, Gedik Y, Okten A, Soylu H, Değer O. Absorption of iron from grape-molasses and ferrous sulfate: a comparative study in normal subjects and subjects with iron deficiency anemia. Turk J Pediatr. 1997 Oct-Dec;39(4):465-71.

iii Nazir L, Samad F, Haroon W, Kidwai SS, Siddiqi S, Zehravi M. Comparison of glycaemic response to honey and glucose in type 2 diabetes. J Pak Med Assoc. 2014 Jan;64(1):

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vi Swithers, S. Artificial sweeteners produce the counterintuitive effect of inducing metabolic derangements. Trends Endocrinol Metab 2013; 24(9):431-441.

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viii Yang, Q. Gain weight by "going diet?" Artificial sweeteners and the neurobiology of sugar cravings: Neuroscience 2010. Yale J Biol Med, 83(2):101-108.

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x Malik VS, Pan A, Willett WC, Hu FB. Sugar-sweetened beverages and weight gain in children and adults: a systematic review and meta-analysis. Am J Clin Nutr. 2013 Oct;98(4):1084-102. doi: 10.3945/ajcn.113.058362. Epub 2013 Aug 21.

xi Kell KP, Cardel MI, Bohan Brown MM, Fernández JR. Added sugars in the diet are positively associated with diastolic blood pressure and triglycerides in children. Am J Clin Nutr. 2014 Jul;100(1):46-52. doi: 10.3945/ajcn.113.076505. Epub 2014 Apr 9.

xii Maki KC, Nieman KM, Schild AL, Kaden VN, Lawless AL, Kelley KM, Rains TM. Sugar-sweetened product consumption alters glucose homeostasis compared with dairy product consumption in men and women at risk of type 2 diabetes mellitus. J Nutr. 2015 Mar;145(3):459-66. doi: 10.3945/jn.114.204503. Epub 2015 Jan 7.

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xv Scourboutakos MJ, Semnani-Azad Z, L'Abbé, MR. Added sugars in kids' meals from chain restaurants. doi:10.1016/j.pmedr.2014.11.003

xvi Wang J, Shang L, Light K, O'Loughlin J, Paradis G, Gray-Donald K. Associations between added sugar (solid vs. liquid) intakes, diet quality, and adiposity indicators
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xviii Lee AK, Binongo JN, Chowdhury R, Stein AD, Gazmararian JA, Vos MB, Welsh JA. Consumption of less than 10% of total energy from added sugars is associated With increasing HDL in females during adolescence: a longitudinal analysis. J Am Heart Assoc. 2014 Feb 26;3(1):e000615. doi: 10.1161/JAHA.113.000615.

xix Stanhope KL, Medici V, Bremer AA, Lee V, Lam HD, Nunez MV, Chen GX, Keim NL, Havel PJ. A dose-response study of consuming high-fructose corn syrup-sweetened beverages on lipid/lipoprotein risk factors for cardiovascular disease in young adults. Am J Clin Nutr. 2015 Jun;101(6):1144-54. doi: 10.3945/ajcn.114.100461. Epub 2015 Apr 22.

xx Hendry VL, Almíron-Roig E, Monsivais P, Jebb SA, Neelon SE, Griffin SJ, Ogilvie DB. Impact of regulatory interventions to reduce intake of artificial trans-fatty acids: a systematic review. Am J Public Health. 2015 Mar;105(3):e32-42. doi: 10.2105/AJPH.2014.302372. Epub 2015 Jan 20.

xxi Downs SM, Thow AM, Leeder SR. The effectiveness of policies for reducing dietary trans fat: a systematic review of the evidence. Bull World Health Organ. 2013 Apr 1;91(4):262-9H. doi: 10.2471/BLT.12.111468. Epub 2013 Feb 4.