School Nutrition Association


We note that the DGA recommendation to eat less than 10 p.c of calories from saturated fatty acids makes no specific exclusion of stearic acid and, as an alternative, pertains to the consumption of whole saturated fatty acids (Ref. 28). Because the DRV is based on the intake of all saturated fatty acids, willpower of p.c DV can be primarily based on content material of all saturated fatty acids in the individual meals. We decline to change the order of vitamins on the label to decrease the prominence of total fats. The itemizing of the amount of complete fat in a product offers valuable info to the buyer concerning the nutrient profile of a food.

The preamble to the proposed rule mentioned the absence of an AI and RDA for complete fats and the way the IOM established an AMDR for complete fat consumption of 20 to 35 percent of power for adults and an AMDR of 25 to 35 % of energy for children age four to 18 years. (The AMDRs are related to decreased danger of persistent illnesses, similar to CHD, while providing for adequate consumption of important nutrients.) We noted that the 2010 DGA acknowledged the IOM’s AMDR and indicated that total fat consumption ought to fall throughout the AMDRs set by the IOM.

Using the newest knowledge from the Gladson database , we calculate that, based on the Gladson values, there may probably be greater than 5,000 meals remaining with declarable ranges of trans fat, after removing of PHOs. Thus, it is premature to think about eradicating trans fats from the Nutrition Facts label right now. We expect there to be a great deal of reformulation of merchandise over the subsequent three years, and we might want to evaluate the remaining trans fats content in foods, each from approved or doubtlessly approved food additive uses of PHOs and from naturally occurring trans fats, after the anticipated reformulations have occurred. We will then be able to contemplate whether, in light of any remaining trans fats content material in foods, declaring trans fat on the label continues to help customers in sustaining healthy dietary practices.

Protecting And Maintaining Bone Health

We mentioned, within the context of the location of added sugars on the label, our plan to conduct a client examine to assist enhance our understanding of how customers would comprehend and use the new information and to publish the results of the patron research when available . We printed the outcomes of our consumer analysis in a supplemental proposed rule to current these examine findings (80 FR 44303; July 27, 2015), and supplied the raw data for the patron study in response to requests for such information (80 FR 54446; September 10, 2015). Contrary to what the comment instructed, the buyer analysis studied client reactions to the declaration to assist inform our future educational efforts related to food labeling and was not conducted for the purpose of determining whether we had the requisite scientific foundation to declare added sugars beneath part 403 of the FD&C Act .

We agree that an individual’s caloric needs can vary; nevertheless, we disagree that the reference caloric consumption degree ought to be a worth aside from 2,000 calories or that there should not be one at all. As we acknowledged in the preamble to the proposed rule, the reference calorie intake degree is not used as a goal for caloric intake, however somewhat to set DVs for total fats, saturated fat, whole carbohydrate, protein, and dietary fiber .

What Is A Balanced Diet?

While we agree that it is important for customers to think about the quantity of saturated and trans fats in a product, these fatty acids are parts of total fats. They are indented and listed beneath total fats on the Nutrition Facts label so that customers can see that they are part of the entire fat declaration. If the declaration of the amount of complete fat in a product is separated from the declaration of its elements, as advised within the comment recommending its placement under carbohydrate and protein, it might seem as if saturated and trans fats aren’t part of the total fat declaration. Furthermore, the comment didn’t explain how eradicating the declaration of the p.c DV for total fats from the label will assist customers focus on replacing saturated fat with monounsaturated fat, particularly if the whole gram quantity of total fats in a serving of a product remains to be declared on the label. Therefore, we decline to remove the declaration of the percent DV for complete fat from the label.