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Government Relations: Regulatory InteractionPMA Comments on Serving SizesJune 17, 2005
The Produce Marketing Association (PMA) is pleased to submit these comments on the Food and Drug Administration’s advance notice of proposed rulemaking "Food Labeling: Serving Sizes of Products That Can Reasonable Be Consumed at One Eating Occasion; Updating of Reference Amounts Customarily Consumed; Approaches for Recommending Smaller Portion Sizes.”
PMA is the largest global not-for-profit trade association representing companies that market fresh fruits and vegetables. We represent companies throughout the food distribution chain that market more than 90% of fresh produce sold at the consumer level. We are funded primarily by members’ dues, revenues from exhibits, product sales, and meeting registrations.
Like the U.S. government and other health authorities, PMA recommends that consumers eat five or more servings of fruits and vegetables each day. Fresh produce plays an important role in efforts to improve the public’s health by offering flavorful, nutritious, and convenient products that will help stem the obesity epidemic.
Consumers, however, are confused about what a “serving” is, and government information about serving sizes differs. PMA believes that accurate, understandable information about serving sizes will help eliminate that confusion and encourage Americans to make appropriate, healthful choices about their diets. FDA is seeking information about “serving size” as it relates to the Nutrition Facts Panel that appears on or near foods. The fresh fruit and vegetable industry is subject to a voluntary nutrition labeling program under FDA and does make use of the Nutrition Facts Panel to inform consumers about the nutrition profiles of the 20 most frequently consumed fruits and 20 most frequently consumed vegetables (listed in the table below, Appendix A).
For purposes of implementing provisions in the Nutrition Labeling and Education Act of 1990 (NLEA) (Public Law 101-535), FDA has defined “serving” or “serving size” to mean: “the amount of food customarily consumed per eating occasion by persons 4 years of age or older, which is expressed in a common household measure that is appropriate to the food.”
In addition, The Dietary Guidelines for Americans is published jointly every five years by the Department of Health and Human Services (HHS), of which FDA is a key agency, and the U.S. Department of Agriculture (USDA). The guidelines provide authoritative advice for people two years and older about how good dietary habits can promote health and reduce risk for major chronic diseases. The 2005 edition of the guidelines was released January 12, 2005.
In this most recent edition of the Dietary Guidelines for Americans, serving size for fruits and vegetables is not defined as “the amount of food customarily consumed per eating occasion.” Rather it is defined as one-half cup: Fruits and Vegetables: Four and one-half cups (nine servings) of fruits and vegetables are recommended daily for the reference 2,000-calorie level, with higher or lower amounts depending on the caloric level. This results in a range of 2½ to 6½ cups (5 to 13 servings) of fruits and vegetables each day for the 1,200- to 3,200-calorie levels.
PMA conducted consumer research in early 2005 in part to determine consumers’ understanding of the word “serving” as it relates to fresh fruits and vegetables (the executive summary and topline results are included with these comments in Appendix B). Ironically, eight out of 10 consumers think they have a clear understanding of what is meant by a serving of fruits and vegetables, but a series of follow-up questions in the survey suggested otherwise. For example, when asked to express in their own words what a “serving” is, responses were all over the map: from one cup, to a handful, to a one-half cup, to a scoopful.
In addition, PMA’s research found that consumers better understand recommended amounts of food when they are expressed in “cups” rather than “servings.” (More detail is available in Appendix B).
PMA is concerned that these various definitions of the same word, “serving,” only confuse consumers. We ask that the agency find a way to reduce that confusion through information provided about serving sizes on the Nutrition Facts Panel. Any solution would have to meet the agency’s regulatory and statutory obligations and would have to be tested with consumers to ensure that the solution does not exacerbate the current confusion.
One suggestion would be to list the serving size as it is now on the Nutrition Facts Panel and underneath that (or in close proximity) indicate the equivalent number of servings it would provide based on the Dietary Guidelines. No other changes in the label would be needed. For example: Serving Size 2 medium stalks (110g) This amount provides about 1 cup or 2 of your recommended daily servings of vegetables
Orange Serving Size 1 medium (154g) This amount provides about 1 cup or 2 of your recommended daily servings of fruit
FDA’s experience and consumer research will likely find a better solution, and PMA highly recommends that the agency find a way to equate the NLEA serving sizes provided on the Nutrition Facts Panel with the serving information provided in the Dietary Guidelines. When it comes to nutrition information, consumers face a great deal of confusion in the marketplace. PMA and its members would like to see consumers eating the amounts of fruits and vegetables recommended in guidelines for the health of our nation and the health of our industry. Fruits and vegetables are the power players in the fight against obesity and many chronic illnesses. To make informed choices, consumers must have straightforward, non-confusing information available to them.
Because of the way regulations evolve, we are now faced with multiple meanings for the same word: serving.
PMA members in the service wholesale and retail sectors are key players in the nutrition labeling initiative to inform consumers at point of sale. We appreciate the flexibility of this voluntary regulatory program, and we are proud that our members consistently meet the compliance threshold set by FDA. In addition, our members who supply fresh fruits and vegetables to retail outlets often use the Nutrition Facts boxes on their products and packaging to highlight the positive nutrition contributions their products make. We appreciate the agency’s efforts to improve and enhance the nutrition information provided to consumers through agency-regulated programs such as this.
PMA appreciates the opportunity to present these comments. We commend the agency for its thorough review of this and other food issues. Please do not hesitate to call upon us if we can be of further assistance. We look forward to working with you.
Kathy Means, CAE Vice President of Government Relations Produce Marketing Association
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