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Declaring ‘Added Sugars’ Causes Consumer Confusion, Research Shows

Oct 14, 2015

Declarations of “added sugars” on food labels will not help consumers to select healthier options, and they should not be added to the Nutrition Facts panel, IDFA told the Food and Drug Administration in comments filed this week. The comments were in response to a supplemental proposed rule that would add the declaration of a percent Daily Value to the Nutrition Facts panel, in addition to the grams amount of added sugars proposed by FDA last year.

In the comments, IDFA raised concerns about the appropriateness of using the Dietary Guidelines Advisory Committee (DGAC) report as the basis for requiring added sugars labeling and for defining the Dietary Reference Value of added sugars that would be used to calculate the percent Daily Value on food and beverage labels.

The DGAC’s conclusions on added sugars were based on studies that focused mostly on sugar-sweetened beverages, which may not apply to dairy products that contain added sugars. Daily Values are usually based on Dietary Reference Intakes (DRIs) determined by expert panels from the Institute of Medicine, which are specially convened for this purpose. The DGAC was not intended to serve such a role, IDFA noted.

The comments highlighted results of consumer research from the International Food Information Council and a subsequent review of the data from FDA’s own consumer research, each demonstrating that the declaration of added sugars as part of the Nutrition Facts panel can exacerbate consumer confusion about how much total sugar is in a product and the healthfulness of products.

Since FDA did not update the definition of added sugar in the supplemental proposed rule, IDFA reiterated its concern that the proposed definition is inappropriately broad, because it could potentially include lactose and dairy ingredients that have lactose as the primary component.

The supplemental proposed rule also addressed the Daily Value footnote that appears at the bottom of Nutrition Facts panels. IDFA agreed with FDA’s proposed update to this statement and requested one small change to clarify that the information in the footnote applies to all foods and beverages.

Prior to filing these comments, IDFA joined four other organizations in sponsoring a consumer study that garnered findings similar to the other consumer studies. This study also demonstrated that the declaration of added sugars on a label increases consumer confusion about the healthfulness of the foods. The sponsors submitted a separate set of joint comments highlighting these results.

IDFA’s full comments can be found here. Members with questions may contact Cary Frye,vice president of regulatory and scientific affairs, at or Michelle Matto, IDFA's nutrition and labeling consultant, at

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