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Saturday, April 21, 2007
The Farce of the FDA’s WebsiteMichael brought up a very good point in the comments here. Where is the proof that Big Chocolate is trying to degrade the standards of chocolate? If you’ve gone through the files that are up for public view listed under 2007P-0085: Adopt Regulations of General Applicability to all Food Standards that would Permit, within Stated Boundaries, Deviations from the Requirements of the Individual Food Standards of Identity you will see that there is a letter from the FDA, a letter about a phone conversation between the FDA and the Grocery Manufacturers Association and then two documents from the GMA (with co-signatories): the cover letter and the citizen petition. (PDFs) Nowhere in these documents does it say anything specifically about allowing a one hundred percent swap of cocoa butter in chocolate for vegetable fats to be called chocolate. However, in that Citizen Petition it mentions (page 4) that there is an Appendix C ... a handy chart that breaks things down. But where is Appendix C? It’s sure not on the FDA’s website. I have it (thanks to Gary Guittard) and you can view it right here. Though it’s only a brief explanation of everything asked for in the proposed changes, it’s quite clear in the first example in the second column that they are asking to swap cocoa butter for other vegetable fats. Since the Citizen Petition had many signatories, and the primary one was the Grocery Manufacturers Association, not the Chocolate Manufacturers Association, I decided to contact them for an official statement of their position. This is what I said:
I got this reply:
This was what the attached letter said:
As for the confusion about the changes not being entirely public (honestly, I’m not sure what else is in there), it is completely deplorable that the public comment period on these proposed changes ends on Wednesday, yet to this date there has been no coherent posting on the FDA’s website as to what we’re commenting on. I was a bit panicked at first, after all, I was just getting my information from the Don’t Mess with Our Chocolate website. I actually waffled for a moment ... I can see a case being made for looser standards when it comes to using newer ingredients and keeping in step with other countries. But there came a reality check for me that I wasn’t just making this up in my head on the basis of one little old website. There have been quite a few articles written about this, with comments from the industry itself. I’m not sure why Hershey would respond to it (as they did in this article) if it weren’t true. I’ve also talked to two other journalists, one from ABC News and the other from Bloomberg. But yes, it would be nice to get a hold of the actual document. Wouldn’t it? 
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Comment by
Rodney North on 4/23/07 at 8:02 am #
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Comment by
Bill Brown on 4/24/07 at 5:06 am #
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Comment by
Philippe Fossier on 4/24/07 at 11:09 am #
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Comment by
Cybele on 4/24/07 at 11:14 am #
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Comment by
desertwind on 4/24/07 at 1:37 pm #
Commenting is not available in this channel entry.Cybele,
That’s some great, persistent, and really helpful sleuthing you did. Thank you on behalf of everyone who believes in real chocolate.
I find Appendix C alarming on several counts unrelated to chocolate. It would allow salt and sweetener substitutes “where the standard allows at least one sweetener.” It would allow “enzyme-modified egg yolk in place of regular egg yolk” and reconstituted milk in yogurt. It would allow for processes that would have the “same effect” as aging cheese. It would allow food spahetti made with 51% whole wheat flour to be called “whole wheat spaghetti”.
Terms like “ingredient interchangability” I find very disturbing. Basically what these changes would mean is that if the manufacturers can make something taste sort-of like real food, they will be allowed to label it as real food.
Hi,
I heard you on NPR, Talk of the Nation.
I am appalled by the endless watering down
of food standards by the Federal Govt.
We should be clamoring for quality, standards and integrity of food products rather than endlessly defending against the assaults of
the bulk food processors to denature fine products in the pursuit of additional profits.
I respect profits and have no issue with low quality products as long as they are not misleading consumers.
If it is not chocolate, call it something else.
Can we stil contact the FDA and be heard ?
Thank,
Philippe
Philippe - absolutely - go to this page:
http://dontmesswithourchocolate.guittard.com/howtohelp.asp
They have a tutorial and link to the FDA’s open comment page.
Bill - yes, there are many other things hidden inside the new proposal. While I think that there’s too much sodium in many processed foods, I don’t know if throwing potassium salts in there instead is going to be any better for me.
I don’t know what genius came up with enzyme modified egg yolks ... I mean, what’s wrong with just plain old egg yolks? Just because you can do something doesn’t mean you should.
Rodney - yes, and once we get people clamoring for quality, we can get them clamoring for equity while we’re at it!
Cybele, this comment made on Steve Gilliard’s News Blog might interest you:
The National Cattlemen are probably in on this docket because one of the rule changes would allow processes to be used that are not the ones named, but produce results that *look like* the named process: ie, ‘roast’ meat would not actually need to be roasted, if the process used produced the *appearance* of roasting. (Think grill marks done with a pencil iron. Think the food photos in magazines, where they look perfect.)
I’m sure that’s not the only one. It’s a long petition.
—P J Evans
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