Specialty Food Magazine

Summer 2020

Specialty Food Magazine is the leading publication for retailers, manufacturers and foodservice professionals in the specialty food trade. It provides news, trends and business-building insights that help readers keep their businesses competitive.

Issue link: https://www.e-digitaleditions.com/i/1256204

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Page 85 of 91

• Principle 10: Define "commodity area" and also make sure that small and very small businesses are protected from definitions determined by commodity groups. • Principle 13: Simplify to require that food standards incorporate existing regulations by reference and allow demonstrated conflict to serve as grounds to eliminate an existing standard. Science-Driven Evaluation Criteria for an SOI Petition Should Be Predictable Food standards should be straightforward, protect consumers from economic adulteration (and honest manufacturers from unfair competition), meet their expectations, and allow manufacturers to innovate and improve foods. The SFA believes this can be accomplished by adopting fewer, but mandatory, criteria against which both new and existing food standards should be measured. Food standards should be based on objective data and reflect what consumers expect from and understand of the defined foods. The standards should be as simple as possible and flexible in how they allow manufacturers to achieve the expected results. When innovation demonstrates that other ingredients or processing techniques can achieve the same results, then the standard can be modified based on expert consensus. Finally, the criteria should rely on existing regulations and require international harmonization so that food standards are predictable and universal. Objective, predictable outcomes help both consumers and manufacturers and provide a path forward to modernize food standards consistent with the Nutrition Innovation Strategy. ingredients, regardless of whether the product was a standardized food. The NLEA also required the listing of nutrition facts on packaged foods. Today, many other items on a food label are much more important in evaluating the healthfulness of a product than the name specified by a SOI, and the restrictiveness of current SOIs can make producing healthier options unlawful. The approach to modernizing standards of identity should be science-driven, employing scientific experts and consumer data and to establish objective criteria that support innovation in production practices while preventing economic adulteration by reflecting consumer perceptions. General Principles Require Significant Revision SFA recommends that Principles 1, 4, 5, 6, 8 and 12 be eliminated. Suggested changes in the following principles include, but are not limited to: • Principle 2: Require that the name of a food subject to an SOI must be based on existing, documented uses of the name (or similar names) among a majority of consumers purchasing the food or, for a new food, be based on a reasonable consumer's likely understanding of the name as established through consumer studies. • Principle 3: Require that an existing, revised or proposed food standard only specify ingredients or describe a manufacturing or cultivation process when they are necessary to produce the food's characteristics as recognized by a majority of consumers. • Principle 7: Require that revised or proposed SOI align with CODEX when a CODEX standard exists. Permit a petition to remove an SOI if a standard does not align with CODEX. SFA would like to thank Jeni Lamb Rogers, J.D., M.S. of the PSL Law Group in Boulder, Colorado for her contributions to this article and the SFA comments to FDA. SUMMER Ron Tanner is vice president of education, government, and industry relations for the Specialty Food Association.

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