The authority for nutrition labels is under the Food, Drug & Cosmetic Act, completely different from the FPLA, And the agency rules are written byt the FDA rather than the FTC. I found links to a guide and the detailed rules: http://www.cfsan.fda.gov/~dms/2lg-toc.html http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=ebf41b28ca63f43546dd9b6bf3f20330&rgn=div5&view=text&node=21:2.0.1.1.2&idno=21 Right or wrong, the government requires the format for Calories. The only permitted option is that the energy in kilojoules may be stated in parentheses after the numerical value. "Calories" may not be captioned "energy" or even kilocalories. However, in the US, nutritional calories are always "big-C" Calories or kilocalories. Since the calorie and Calorie are deprecated units, they should change to energy in kilojoules. I don't see this happening soon. I can't find a requirement that the space between value and unit must be omitted, but it is shown thus by example throughout the guide document above. I guess FDA should be made to attend a remedial NIST "learn to use SI properly" course. As for sodium, I think it is fine as it is. The concern is the sodium. Table salt is probably the many contributor, but how else would you include baking soda, MSG and the numerous other food additives that add to the sodium. In the analysis of minerals in water solution, it is customary to describe each as though it was present in elemental form, although it is really in the form of dissociated ions. If both table salt and baking soda were in a food, it would not be possible to state which sodium ions came from the salt and which from the baking soda. Further, the total weight of those two substances would not describe the total amount of sodium unless you knew the ratios. --- On Wed, 4/8/09, Stan Jakuba <[email protected]> wrote:
From: Stan Jakuba <[email protected]> Subject: [USMA:44480] Re: FPLA 2010 To: "U.S. Metric Association" <[email protected]> Date: Wednesday, April 8, 2009, 9:18 AM While on the food labeling issue, in my collection of labels from many countries, only the U.S. is denying the existence of energy in food. One wonders how the fattest people in the world become so obese if the amount of the label-specified fat would not sustain a pet. I am referring, of course, to the mysterious "calories" in the column of protein, fat, calcium,....... See the attachment (included for the non-Americans). Other nations print the word "energy" (in the respective language), and list value in kJ (sometimes concurrently with kcal). This U.S. labeling specialty makes it possible to see the same chocolate/candy-bar portrayed on two different TV channels in the U.S. as follows: One commercial shows the bar on the background of jumping, celebrating, happy teenagers, the message conveying: Buy it, eat it, be happy; it has lots of energy. Energy is good for you. Can't eat too much of it. A nutrition promoting channel next to it shows the same candy bar with the message of rotten teeth and obese children slumbering about while being told: The product is bad for you. It has calories. Calories are bad. Stay away from them. Don't buy it, don't eat it. I'd like to understand the mind-set of the FPLA official who did not recognize that calorie is a unit, not a quantity. The same person perhaps, who is responsible for the missing spaces in the metric values while they exist in the I-P values. There is another mystery on the U.S. labels and I hope there is a chemist/nutritionist on this forum who can explain why the nutritional labels list sodium, a highly toxic element nobody can eat. I'd say "salt" or "NaCl" or some other name if there are several different salts involved, but "sodium"? Stan Jakuba ----- Original Message ----- From: "Paul Armstrong" <[email protected]> To: "U.S. Metric Association" <[email protected]> Sent: 09 Apr 05, Sunday 20:44 Subject: [USMA:44412] Re: FPLA 2010 > > > On 2009-04-05, at 14:47-0700, <[email protected]> wrote: > >> Attached is a second draft of FPLA 2010 by Eugene A. Mechtly to include >> contributions by Pat Naughtin and by Stan Jakuba. >> <FPLA-4-5.pdf> > > > Nice job. > > Did you see: http://gometric.us/xwiki/bin/view/Labeling/ ? > I posted it a while ago with a few ideas on revisions. Pick it apart as > you need. > > Some thoughts: > * Section 2: "Supplementary declarations ... or their multiples." I'd add > "in the same font of a size no larger than the primary indicators" so > that they can print it smaller, but not 10x the size of the primary > indicators. > * I would add full words after the abbreviations (e.g. "if on a package, > labeled in terms of mass, shall be expressed in g or its multiples;" make > it "g (grams) or its multiples;" > * I would probably use the strike through method of showing your > differences as that seems to be accepted practice. Similarly, show a full > FPLA with your changes included for context. > * "(iv) if on a container labeled in terms of volume or fluid measure > shall be expressed in m or its multiples, or ml, mL, or L." > ** I'd reword the end as "L (liters) or m³ (cubic meters) or their > multiples". This both puts liters first (so you don't end up with people > trying to sell 10 cubic centimeters of tomato paste) and makes the > language both simpler and consistent. > * 3(A)(II) "multiples" needs to be indented. > * Consistently use L or l (preferably L) in the document. > > Paul > > -- Make measurement make sense. > http://gometric.us >
