January 22, 2024
We appreciate the opportunity to suggest topics to be discussed at the “Virtual Public Meeting and Listening Sessions on Strategies to Reduce Added Sugars Consumption in the United States.” We support the FDA’s efforts to help consumers adopt healthier dietary patterns that conform to the latest nutrition science and federal nutritional guidance.
The National Center for Health Research (NCHR) is a nonprofit think tank that conducts, analyzes, and scrutinizes research on a range of health issues, with a particular focus on which prevention strategies and treatments are most effective for which patients and consumers. We do not accept funding from companies that make products that are the subject of our work, so we have no conflicts of interest.
Every day, the average American adult, teenager, and child consumes about 17 teaspoons of added sugar, which is substantially more than recommended by the 2020-2025 Dietary Guidelines for Americans.2 NCHR recognizes high sugar consumption as a major burden to public health, increasing the risk of metabolic dysregulation and cardiovascular disease. To have a meaningful impact on sugar consumption, it is important to increase public awareness regarding the risks of high sugar consumption and added sugars, and it is vital for the FDA to establish clear guidelines and mandates aimed at reducing the amount of added sugars to packaged food, beverages, and restaurant food.
Strategies targeted at food and beverage production companies are estimated to have the largest effect on reducing sugar consumption in the United States. Thus, we recommend that the following policies be discussed at the virtual public meeting as they offer effective solutions:
- The FDA should establish targets for added sugar reduction in packaged food, beverages, and restaurant food.
American diets are mainly filled with added sugars from food and drinks bought at stores and restaurants. Unfortunately, consumers have little control over or knowledge of the quantity of added sugars within these products; in fact, three out of four consumers favor policies aimed at reducing added sugars.3 However, the burden of regulating excessive amounts of added sugars into the food supply largely lies on food and beverage companies, whose interests are not always aligned with the interests of the public. Therefore, we strongly recommend that the FDA establish measurable added sugar reduction targets for processed, packaged, and prepared foods and beverages. Specifically, we urge the FDA to incorporate short-term (2-5 years) and long-term (7-10 years) goals of evaluating industry compliance with FDA goals to reduce added sugars in the foods and beverages that they sell. These targets should be consistent with the White House National Strategy on Hunger, Nutrition, and Health as well as the citizen petition filed last year by the Center for Science in the Public Interest and the New York City Department of Health and Mental Hygiene.
Implementing industry standards to help lower added sugars to less than 10% of total daily calories is estimated to prevent more than 2 million cardiovascular events, half a million deaths from cardiovascular disease, and 750,000 new diagnoses of diabetes.4
This would result in an estimated savings of more than $160 billion in lifetime net costs.5 Thus, the potential benefits of reducing sugar intake through FDA regulation and industry compliance is significant and should be a key strategy discussed at the virtual meeting.
- The FDA should require simple, attractive nutrition labels on the front of packages for foods and beverages.
Lack of awareness and understanding of the specific nutrient content of package foods and beverages also contributes to Americans’ overconsumption of added sugars. The current standards set for nutrition labels and labeling of packaged foods are not working, since most consumers do not use the nutrition label panel when choosing what foods to buy.6 Current labels may be difficult to understand and are therefore ignored. Simple yet engaging front-of-package labels to packaged foods can clearly indicate if a food is high in sugar and help influence a consumer’s food choices. Similar initiatives have been taken in countries such as Chile, which have been shown to decrease the number of high-sugar food items that are purchased. This can empower consumers with information to make better food choices.
- The FDA should mandate that added sugars are disclosed at restaurants.
The lack of information regarding added sugars in restaurant foods and beverages is a significant public health issue. Consumers have no way of knowing how much added sugar is in restaurant food products, making it difficult for them to make informed choices when ordering from restaurants.
The FDA holds the power to mandate that restaurants disclose information about added sugars if it deems such a measure essential for aiding consumers in making healthier dietary choices. The agency has previously exercised this authority by necessitating an added sugars disclosure on the Nutrition Facts Label, so it could readily implement a similar requirement for restaurants. Aligning menu labeling regulations with the Nutrition Facts Label could serve as a straightforward and effective strategy for the FDA to underscore the significance of added sugars as a nutrient and promote a decrease in their consumption.
The availability of information concerning added sugars is not only crucial for consumers but also for local and state policymakers as well as public health researchers. This data is indispensable for the creation and evaluation of policies aimed at curbing the presence of added sugars in restaurant meals. For example, in November 2023, the Sweet Truth Act was enacted in New York City, necessitating warnings on menu items high in added sugars. However, in the absence of an FDA requirement for added sugar disclosures, the majority of restaurant items remain exempt from this law. Therefore, it is crucial for the FDA to enforce the disclosure of added sugars in restaurants, to support New York City’s initiatives and set a precedent for other jurisdictions to follow.
- The FDA should ensure that foods and beverages with low- and no-calorie sweeteners are safe for human consumption and better regulate labeling of foods with artificial sweeteners.
While it is important to limit the amount of added sugars found in foods popular in the American diet, added sugars should not be replaced with artificial sweeteners that are not proven safe for long-term use, especially by children. Artificial sweeteners mimic the effects of regular sugars in the body that may lead to weight gain.8 These sweeteners are also linked to hormone disruption, an increased risk of cardiovascular issues and an increase in type 2 diabetes.8 Food products that include artificial sweeteners as an ingredient should list those ingredients very conspicuously on their packaging.
NCHR strongly urges the FDA to prohibit foods containing sugar substitutes from being labeled “healthy.” Although low- or no-calorie sweeteners are not considered added sugars and are not addressed in this proposal, several studies raise worrisome questions about the risks of sugar substitutes. For example, in draft guidelines released in 2022, the World Health Organization (WHO) warned against using sugar substitutes to lose weight or improve health. While the WHO acknowledges that more research is needed to determine a definitive connection, the organization says long-term harm from sugar substitutes is possible, including increased risk of obesity, type 2 diabetes, heart diseases, and mortality.9 Some of these sweeteners may also alter the normal flora of the gut – which can lead to changes in metabolism.[1] For these reasons, we do not support labeling any food or drinks containing these sweeteners as “healthy.”
References:
[1] CDC. Know Your Limit for Added Sugars. Centers for Disease Control and Prevention. Published November 28, 2021. Accessed February 13, 2023. https://www.cdc.gov/nutrition/data-statistics/added-sugars.html
2 Dietary Guidelines for Americans, 2020-2025. (n.d.). Accessed January 16th. https://www.dietaryguidelines.gov/sites/default/files/2020-12/Dietary_Guidelines_for_Americans_2020-2025.pdf
3 Primary analysis of NHANES 2017-2018 Consumer Behavior Phone Follow-up Module conducted by CSPI. 2022.
4 Center for Science in the Public Interest. Widespread support for voluntary added sugars reduction targets for the U.S. food industry. May 2023. https://www.cspinet.org/resource/widespread-support-voluntary-added-sugars-reduction-targets-us-food-industry.
5 Shangguan S, Mozaffarian D, Sy S, Lee Y, Liu J, Wilde PE, Sharkey AL, Dowling EA, Marklund M, Abrahams-Gessel S, Gaziano TA. Health impact and cost-effectiveness of achieving the national salt and sugar reduction initiative voluntary sugar reduction targets in the United States: A microsimulation study. Circulation. 2021;144(17):1362-1376.
6 The model assumed a 100% compliance scenario in which industry fully met the 40% sales-weighted mean sugar reduction targets for sugar-sweetened beverages and the 20% sales-weighted mean sugar reduction targets for all other categories by 2026.
7 Neal B, Crino M, Dunford E, Gao A, Greenland R, Li N, Ngai J, Ni Mhurchu C, Pettigrew S, Sacks G, Webster J. Effects of different types of front-of-pack labeling information on the healthiness of food purchases—A randomised controlled trial. Nutrients. Nov 24 2017;9(12):1284.
8 Artificial Sweeteners: Do They Help You Lose Weight or Gain it? Are they Safe? (2023, August 1). National Center for Health Research. https://www.center4research.org/artificial-sweeteners-weight-safety/
9 Rios-Leyvraz M, Montez J. Health Effects of the Use of Non-Sugar Sweeteners: A Systematic Review and Meta-Analysis. World Health Organization; 2022:210. https://www.who.int/publications/i/item/9789240046429