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In general, the FDA requires that all ingredients be listed on food labels by their usual or common names. Reading the ingredient list is truly the best way to learn about the product. That said, there are regulations that allow certain ingredients to be presented in ways that may be deceptive or misleading. For example, some ingredients may be given names that fail to fully describe them, and thus they may be more heavily processed than most consumers realize. Milk can refer to fresh milk, concentrated milk, dry milk powder, or reconstituted milk made with added water. This is true not only for foods that contain milk as an ingredient but also for milk sold to drink. Buttermilk, skim milk, whey, and cream can also refer to products that have been dried, concentrated, or reconstituted. Eggs can refer to liquid, dried, or frozen eggs; the same is true for egg yolks and egg whites.
Confusion can also occur from the use of less-familiar names for ordinary products. For example, many products marketed as “natural” foods use the terms cane sugar or beet sugar, when the ingredient in question is simply refined white sugar. In fact, the FDA stipulates that cane sugar, sugar, and sucrose are interchangeable terms. Similarly, white flour is often listed as wheat flour or unbleached white flour. Although not untrue, such descriptions serve to draw consumer attention away from the fact that the ingredient is ordinary white flour, a highly refined product. All wheat flour is unbleached unless otherwise specified or unless the bleaching additive is included in parentheses as an additional ingredient. Historically, the ingredient that has been most frequently disguised on food labels is undoubtedly monosodium glutamate (MSG). All protein hydrolysates, or hydrolyzed proteins (whether from casein, soy, beef, or other sources), are simply forms of MSG. Textured vegetable protein and yeast extract also contain it.
Previously, these ingredients could be concealed by listing them as natural flavor or flavoring, but today the FDA requires that virtually all protein hydrolysates be listed individually. The exception involves those present in meat products, which are regulated by the USDA rather than the FDA. Any meat or poultry products that contain flavoring, flavor, or natural flavor may contain protein hydrolysates. Some ingredients (most notably, oils) can be listed even if they are not always present in the product. When a manufacturer includes a phrase such as “cottonseed, soybean, and/or canola oil,” the cheapest available oil is usually being used. These oils are highly refined and, quite likely, genetically engineered. There is currently no requirement that food containing genetically modified organisms (GMOs) display that fact anywhere on the label. However, provisions in the Food, Drug, and Cosmetic Act make it possible to identify certain genetically modified ingredients.
When a food of any sort differs from the traditional version in nutritional content, its name must reflect the altered quality. Therefore, soybean oil that has been genetically engineered to increase the oleic acid (an omega-9 fatty acid) content must be listed as “high oleic acid soybean oil.” Any ingredients that are listed as being high or low in something have been intentionally altered, and may be genetically modified. Food additives generally appear at the end of the ingredient list, which is organized in descending order by weight. Often, the last several ingredients are preceded by a statement such as “contains less than 2% of the following.” However, taken together, these ingredients may constitute a much larger percentage. Although most additives must be named on the ingredient list, incidental or indirect additives that are present in trace amounts, often as part of another ingredient, are exempt. These are most likely to be found in heavily processed or prepared foods such as soups, sauces, seasoning packets, breaded chicken or fish, and frozen entrées.
You can often use the length of the ingredient list as a tool to quickly estimate how heavily processed a food may be, since more ingredients and more additives tend to indicate more processing. Next week we'll discuss the accuracy of nutrition labeling information as well as the FDA's proposed changes to nutrition labels.
This article excerpt was selected from the Fall 2014 Price-Pottenger Journal of Health and Healing.
– JENNIFER HANDY
- Food; Designation of Ingredients, 21 C.F.R. Sect. 101.4 (2013). 19.
- Sucrose, 21 C.F.R. Sect. 184.1854 (2013). Flour, 21 C.F.R. Sect. 137.105 (2013).
- Schwartz GR. In Bad Taste: The MSG Syndrome. New York, NY: Signet; 1988.
- Ingredients Statement, 9 C.F.R. Sect. 381.118 (2013).
- Misbranded Food, 21 U.S.C. Sect. 343 (2013).
- Definitions, 21 U.S.C. Sect. 321 (2013). Food and Drug Administration.
- Draft guidance for industry: voluntary labeling indicating whether foods have or have not been developed using bioengineering; availability. Fed Regist. 2001; 66:4839.
Published in the Price-Pottenger Journal of Health and Healing
Summer 2014-18 | Volume 38, Number 2
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