Farm Women United

3064 State Route 3005, Meshoppen, PA 18630

(570) 618-3877

farmwomenunited@gmail.com

January 12, 2023

URGENT TIME-SENSITIVE ACTION ALERT

FARM WOMEN UNITED (FWU) ENCOURAGES ALL

INTERESTED

PARTIES

INCLUDING INDIVIDUALS AND ORGANIZATIONS

THAT ARE CONCERNED IN ANY WAY

ABOUT

OUR NATION'S FOOD SUPPLY

TO SUBMIT PUBLIC COMMENTS TO THE U.S. FOOD AND DRUG ADMINISTRATION (FDA)

BY

FEBRUARY 16, 2023, 11:59 PM ET, ABOUT

FDA'S “PROPOSED RULE” ON THE USE OF THE WORD “HEALTHY” ON FOOD LABELS

Background:

Thanks go to Sherry Bunting, who, writing in the November 25 2022, issue of Farmshine, reported that on September 29, 2022, FDA issued a Proposed Rule concerning “Food Labeling: Nutrient Content Claims; Definition of Term 'Healthy'” about which she has raised very serious concerns.

It is important to emphasize that the deadline for public comments on the Proposed Rule, originally December 28, 2022, has been extended to February 16, 2023.

The 35-page Proposed Rule is a difficult read but an important one for those who want to know what food the government believes merits the FDA “Healthy” designation and what foods, by omission, the government deems unhealthy.

One important red flag, among many, is the elimination of the meat and poultry food group. The replacement food group is simply named “protein.” The Proposed Rule limits saturated fat to 1 gram per serving for meat, making it nearly impossible for farm-raised meat, even grass-fed, to qualify for the “Healthy” designation. Some other foods can have 2 to 4 times as much saturated fat per serving as the limit for meat and still be deemed “Healthy.” An example of the mind-set behind FDA's Proposed Rule is that the often over-processed plant-based oils are qualified to be labeled “Healthy” but not butter!

Draw your own conclusions.

The Proposed Rule acknowledges that 90% of Americans do not consume enough “dairy” but remains steadfast in declaring that only fat-free or low-fat dairy products are “Healthy.”

FDA now includes soy beverages and soy yogurt alternatives in the “dairy” classification and seems open to the possibility that more plant-based products could be added to the “dairy” classification in a “special circumstance.” This is an obvious misclassification by our government.

The Proposed Rule is biased against animal agriculture, while seemingly encouraging “product innovation” and “industry innovation” in the creation of food that can be labeled as “Healthy.”

Recommended Action:

Anyone concerned about food choices, especially meat and full-fat dairy products, and their availability in the future, needs to send a comment to FDA by February 16, 2023.

For information about the Proposed Rule and how to submit a comment or to read comments that are already posted, please visit:

https://www.regulations.gov/document/FDA-2016-D-2335-1152

FDA needs to hear from you.

Please share this information with your contacts.

For further information, contact Gerald Carlin, FWU

Chair of Policy Development

FWU submitted a comment on the FDA Proposed Rule that was posted online on December 28, 2022. The FWU comment is included below for your information.

FWU Submission to the FDA on Term "Healthy"

Farm Women United Comment Posted December 28, 2022

"Farm Women United (FWU) embraces the civic duty to submit a comment on the proposed rule concerning “Food Labeling: Nutrient Content Claims: Definition of Term 'Healthy'” (Proposed Rule).

First, we will comment on two clear double standards espoused by “current nutrition science” and the Federal Dietary Guidelines. While “whole foods” are promoted in the area of vegetables, fruits, and grains, whole foods in the dairy and farm-raised red meat sector, though very nutrient dense, cannot qualify as “healthy,” by government standards. Further, the Proposed Rule limits sugar, but gives “low and no calorie” and “high intensity sweeteners” a pass.

FWU is appalled to find that a whole food group (meat and poultry) has been eliminated and replaced with “protein,” paving the way for cellular meat and designer plant-based meat replacements that take the place of real meat with little or no knowledge of the long-term impacts on human health. We are also concerned about the overuse of soy, most of which is genetically modified, and the unresolved concerns about any negative impact on human health, along with the hormonal effects of soy on males and females, including children.

In dairy, whole, unaltered, unprocessed milk is the healthiest. The proposed rule may have a negative impact on small, local facilities that produce whole natural dairy products. The more milk is processed and altered, the less nutritious it is and the less digestible it is. Scientists, chemists, and industrialists do not improve the food designed by our Creator. FWU rejects Dietary Guidelines 2020-2025, which put soy beverages and soy yogurt alternatives in the dairy classification. We further object to FDA’s implication that other plant-based beverages and yogurt alternatives could be considered a part of the dairy classification in a “special circumstance.” We acknowledge that some may not want to or may not be able to consume real dairy products. They may seek alternatives. This does not justify the obvious and deceptive misclassification of these products by the government.

FWU also rejects the notion that over-processed plant-based oils are healthier than more natural animal-sourced fats, such as butter.

We are not impressed by terms such as “product innovation” or “industry innovation” as these terms have been used to justify manipulating, extending, over-processing, and rearranging the natural structure of food in order to reach a desired nutrient profile that can be deemed “healthy” whether these nutrients are bio-available or not. We do believe in science. However, we do not necessarily believe scientists, especially those who succumb to pressure, in whatever form, to conform to an agenda-driven consensus. We are keenly aware of the censorship of dissenting scientific thought in the formation of the Dietary Guidelines 2020-2025.

FWU believes, in general, that the most naturally grown, least processed foods, whether it be fruits, vegetables, dairy, meat, poultry, grains, nuts, seeds, etc., are the healthiest, while the less naturally grown and the most processed foods are less healthy, and maybe, truthfully, not even “healthy” at all.

We are particularly concerned that under these proposed federal food regulations, which will control what food can actually be identified as “healthy,” children will be deprived of sufficient saturated fat, which is necessary for their proper growth and brain development. In fact, there is scientific evidence that saturated fat is beneficial and necessary in all stages of life.

The Proposed Rule also does not consider differences in lifestyle and activity level as another common-sense prerequisite to assist in determining the best food choices consumers need to consider.

In general, FWU rejects the Dietary Guidelines 2020-2025 as agenda-driven and, therefore, also rejects the proposed FDA rule concerning “Food Labeling: Nutrient Content Claims; Definition of Term 'Healthy'” as another stark indication that the federal government has lost its way in all matters relating to food by catering to special interests that will directly profit from these proposed food labeling regulations by seizing ever increasing control over the food people eat and how this food is produced, and now, under this Proposed Rule, whether or not even the most basic food can be labeled “healthy.”

The Federal Dietary Guidelines and the Proposed Rule demonstrate absolutely no regard for truth, clarity, honesty, or common sense in determining what food may or may not be labeled “healthy.” This represents a vast government overreach and a bureaucratic boondoggle that will only further confuse the consumer.