Results from a proposed consumer study regarding the labeling of added-sugars content would not be practically useful, IDFA told the Food and Drug Administration in comments submitted late last week. Since no analytical method exists for differentiating between total and added sugars in a finished product, FDA would not be able to enforce labeling requirements for added sugars. IDFA said the agency should forego the research and apply its resources to more urgent needs, like consumer education.

“We respectfully contend that the collection of information regarding labeling of added sugars will not have practical utility, since the agency will not be able to enforce the declaration of added sugars,” said IDFA.

Instead, additional consumer education regarding the content of a healthy diet and how various foods can fit into a healthy eating plan would be a better use of FDA’s resources, the comments said.

In the event that FDA decides to proceed with the study, IDFA recommended changes to the proposed questions for consumers that would add clarity to their responses.

IDFA submitted the comments in response to a Federal Register notice posted in May, asking for input on research designed to examine consumer understanding of possible changes to the Nutrition Facts panel, including the addition of added sugars. This request for comments followed up two earlier requests, one from last December and an earlier Advanced Notice of Proposed Rulemaking, looking for public input on updates to the Nutrition Facts panel.

FDA will use the public comments submitted to make a final decision regarding the proposed consumer research.

• Read IDFA’s comments here.

• Read FDA’s request for comments here.

Members with questions may contact Cary Frye, IDFA vice president of regulatory and scientific affairs, at cfrye@idfa.org, or Michelle Matto, IDFA's nutrition and labeling consultant, at amfoodnutrition@gmail.com.