Folks, It Ain’t Just Chocolate

Boy, was I doing some riveting reading over the weekend.  I’m so glad I chose to spend my kids’ entire nap time tucking into FDA Docket Number 2007P-0085: Adopt Regulations of General Applicability to all Food Standards that would Permit, within Stated Boundaries, Deviations from the Requirements of the Individual Food Standards of Identity.  Yeah, that was a good use of two hours.

This document has gotten a lot of press lately for the effect it might have on how we manufacture chocolate in this country.  Because, let’s face facts, chocolate is the single most important food group.  On any given day of my life, it might be the only one. 

This citizen’s petition, drawn up by the good “citizens” that comprise the Chocolate Manufacturer’s Association (CMA) and the Grocery Manufacturer’s Association (GMA), among a long list of other industry groups, hopes the FDA will relax its standards for how it defines certain foods while still keeping the same name. 

Each type of chocolate has its own definition, but the current requirements for milk chocolate are: at least 10% chocolate liquor, at least 12% milk ingredients, cocoa butter, and sugar.  If this petition were accepted, chocolate and all foods with strict definitions could be subject to “suitable substitutions.”  And we all know what that means: cheaper ingredients.  And who determines what’s suitable?  Perhaps, the same good folks who brought us Olestra. 

Lowering standards would translate into hydrogenated vegetable oils being substituted for cocoa butter.  For sweeteners, the sky would be the limit, but I’m going to take a wild stab in the dark at corn syrup.  And the chocolate liquor could be replaced with, oh, I don’t know, something else brown.  Sign me up for CMA’s Chocolate-of-the-Month Club.

But even more disturbing than the chocolate side of it (and that freaks me out more than you can possibly know) is the fact that all packaged foods would be at risk.  Even things like cheese.  It’s everything that is represented by the following groups and their subsidiaries: the American Frozen Food Institute, the American Meat Institute, the International Dairy Foods Association, the Food Products Association, the Juice Products Association, the National Fisheries Institute, the National Meat Canners Association, the North American Millers’ Association, and the Snack Food Association.  In other words, almost everything in the supermarket.

There might be some legitimate points in this petition somewhere, but I couldn’t really find them through all the intentional vagueness.  In essence, the whole thing read like this:

Hey, you.  FDA.  We know you’re too busy with clinical trials of the various erection medications flooding the market.  Do you really want to spend your time worrying about dumb old food standards?  Are you sure you want us to bother you with every single stupid labeling or ingredient change we want to make?  You don’t, do you?  Okay then.  Don’t worry, we’ll take care of EVERYTHING.

Thanks, GMA.  You’re a peach.  So, I guess that means I’ll have more anal leakage to look forward to.

The FDA has extended its comment period through June 25.  In the meantime, I’m thinking of drawing up a citizen’s petition of my own.

Comments

[Tanna]

I have to think that I would have missed this without the internet. I've already commented on the site. I didn't spend 2 hours reading all the detail but like you I was flabergasted at the overall blanket of the proposal. You paraphrased so beautifully!

[Sally]

I agree with Tanna (another early riser!). I can't quite wrap my brain around what-exactly- they're trying to do, but the Olestra example really helped. Good post Tammy.

[Lisa]

Yeah I first saw this on Cybele's blog and I was horrified. Who the hell do they think they are screwin with our chocolate??

I'm just shocked a group of pre-menstrual women haven't hunted them all down and killed them yet.

And thanks for reminding me about 'anal leakage' I had almost forgotten about it.

xoxo

[sunny12]

This sort of proposal really shows the differences in food policies between the US and Europe (with canada, where I'm from, stuck somewhere in the middle). I bet a European would look at the proposal at point out that most of what Americans claim is chocolate is not really chocolate at all (like white chocolate!), whereas the incredible restrictions in European food policy makes it quite difficult for any new product to break out there.
In Canada I know a legislator was proposing that dairy products had to be identified properly, so the word "creamy" would no longer be able to be used unless there was actual cream in it, and "cheese" (or any other spelling) had to refer to actual cheese, not processed cheez-like products. Many, many people still believe that Cheez-whiz is a bonifide cheese, and that mayonnaise has dairy in it.

[sunny12]

completely unrelated, slashfood.com has some video of rats running around in Boston restaurants. In case you wanted to know.

[Tammy]

Sunny12: Awesome rat footage. You bring up a great point about the differences in legislation around the world. I like your Canadian model where the words used to describe food actually reflect the true ingredients (imagine that). Here, we like our cheese to come in cans and contain no actual cheese.

Lisa: I'm menstrual myself and, therefore, had to delete out all the swearing and death threats.

Tanna: I'm glad you commented. I hope grass roots action like this actually works. Guess we'll find out.

Sally: My favorite line in the document was something to the effect of: customers won't know the difference. Thanks. I'm going to go rip my tongue out right now.