Submission Number: 07774
Received: 7/14/2011 8:31:36 AM
Commenter: Bernard Kreilmann
Organization: Ferrero U.S.A., INc.
State: New Jersey
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
Dear Chairman Leibowitz:
I am sending this letter on behalf of Ferrero USA to express our company’s opposition to the preliminary proposed Nutrition Principles to Food Marketed to Children by the Interagency Working Group (IWG) and strongly urge the withdrawal of these guidelines for the reasons outlined below.
These guidelines and the marketing restrictions set out in the guidelines represent an overreach on the part of the IWG. The 2009 Omnibus Appropriations Act only directed the FTC, USDA, FDA, and CDC to complete a study and provide recommendations to Congress. Instead, the IWG has proposed severe restrictions on the marketing of a large percentage of foods and beverages, including healthy foods.
Moreover, the IWG’s standards are more restrictive than the standards for foods sold under the school lunch program, the WIC program, and even contradict the Administration’s own food recommendations to Americans.
By default, in establishing these severe marketing restrictions, the IWG has created guidelines that limit marketing communications to adults, not just children and adolescents. As a consequence, these guidelines will limit our ability to provide consumers, namely parents, with the information they need to make informed decisions about the foods they buy for their families.
It is for these reasons that we request the withdrawal of the IWG proposal on food marketing restrictions.
President and CEO
Ferrero USA, Inc.