Submission Number: 00687
Received: 7/13/2011 2:45:12 PM
Commenter: James McCarthy
Organization: Snack Food Association
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
The Snack Food Association (SFA) welcomes the opportunity to comment on the Interagency Working Group's (IWG) Food Marketed to Children Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts. SFA is the international trade association of the snack food industry representing snack manufacturers and suppliers, and represents over 400 companies worldwide. SFA business membership includes manufacturers of potato chips, tortilla chips, pretzels, popcorn, snack crackers, and various other salty snacks.
SFA supports the IWG’s efforts to address childhood obesity, an important issue that we continue to combat. SFA believes the voluntary standards are overly restrictive, unattainable, and have no scientific backing to prove their effectiveness. Moreover the proposed definitions, which incorporate the 20 categories of advertising, marketing, and promotional activities identified in the FTC’s food marketing study definitions, would virtually restrict all advertising for our industry’s products being marketed to children and adolescents. These unrealistic standards, if applied, would mandate a “perfect food” halo on products if they were to meet the advertising guidelines. It is well understood that there are no perfect foods as dietary goals have always emphasized the total diet -- not by scrutinizing every nutrient in every food.
Over the years the snack food industry has worked diligently to reformulate its products to meet healthier profiles. Today’s products include a variety of better-for-you options, such as: reduced calorie, whole-grain, low-fat, low-sodium, and 100 calorie portion-controlled packaging. An example of reformulation has been the elimination of virtually all trans fats from our product line. Even with this success, reducing fat and sodium continue to be a goal in our industry.
Our industry continues to work very hard to achieve sodium reduction targets established by the Alliance for a Healthier Generation, the American Heart Association, and the New York City Sodium Reduction Initiative. Although many of our products are now able to meet the interim standard set forth by the IWG, these same products will not meet final standards for sodium and saturated fat.
SFA member companies have been involved for years in efforts to reduce the incidence of obesity. We have endorsed the guidelines developed by the Alliance for a Healthier Generation. Implementation of these first-ever voluntary guidelines for snacks sold in schools has provided healthier food choices for America’s children. SFA is also an active partner in the Healthy Weight Commitment Foundation – a national, multi-year effort designed to help reduce obesity, especially childhood obesity by 2015. The Healthy Weight Commitment Foundation promotes ways to help people achieve a healthy weight through energy balance -– calories in and calories out.
SFA is disappointed that the IWG has failed to recognize several industry-initiated successes; e.g., the reformulation of over 20,000 products to reduce calories, fat, sodium and sugar as stated by the Grocery Manufacturers Association, an 88% decrease in total beverage calories shipped to schools, and most importantly recognition by the Children’s Food and Beverage Advertising Initiative (CFBAI) that marketing self–regulation is working. CFBAI reports that prior to their program some products contained as much as 900mg of sodium. Today the highest is 760. But most products have far less sodium.
Finally, there is no evidence that imposing unrealistically strict advertising standards will have any impact on the weight status of children. Further studies are imperative to ensure that the proposed guidelines would actually have an effect on reducing obesity.
SFA recommends that the IWG withdraw its proposed standards.