U.S. “Whole Seed” versus “Whole Grain” Labeling Alert

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Our position is that whole-seed beans, peas, lentils, chickpeas, flaxseed, mustard, sesame, walnut, pine nut, almonds and other whole seeds should also qualify as “whole grains” under FDA regulations.

[UPDATED] For FoodNavigator summary of this issue, please follow link at the end of this post.

Should a “whole seed” definition apply only to cereals (members of the grass family) or to all seeds (including flaxseed, sesame, beans, chia, lentils…)?

This is still an open question with major consequences for the food industry and consumers alike. Resolution of this issue will determine to what degree non-cereal seeds (grains) will be used in many of the new foods currently under development in the United States.

Although the official Food & Drug Administration’s (FDA’s) comment period ended years ago, the word is that they are still looking for guidance on this matter. Here is how to make your opinion regarding “whole grain labeling” regulations…matter.

The U.S. Food & Drug Administration (FDA) first proposed a definition for “whole grains” in 2006, to be followed by a requisite 90-day comment period. Today (December 2013), a working regulatory definition remains elusive. There is still time for our industry to contribute to this debate.

Earlier this year, attendees of the Nutrition Division luncheon at the AACCI Annual Meeting (Oct 1-4, Albuquerque, New Mexico) learned that the FDA had communicated to a AACCI Nutrition Division delegation that: a) it wanted to make resolution of a “whole grain” definition a priority and b) today, seven years after the formal closing of the 90-day comment period, it was still open to comments that would help the FDA arrive at a proper decision.

This has enormous implications for the U.S. food ingredient and food manufacturing industries. Here are the how, why and what thereof:

  1. The original FDA proposal would only allow cereals (taxonomic members of the grass family) and “pseudocereals” (a very loosely defined term) such as amaranth and quinoa, to be included under this definition. Other whole-seed flours, such as flaxseed, sesame, chickpea or dry bean flours, would not be included even though they are a) more nutritionally rich than cereals and b) utilized in foods in very similar manners to those of cereals (which meets one definition for a “pseudocereal”). There is strong support among some in industry and academia for a broader “whole seed” definition that includes all whole-seed ingredients.                                 [ line space]
  2. Regulatory and nutritional interest in “whole grains” is driven by a recognition that the outer pericarp (bran) layers of the seed are rich sources of nutrients and that removal of the bran during milling diminishes the nutritional value of the seed.  This is true for all seeds, not just cereal seeds. Ergo, the guiding principle behind developing whole-grain definitions should be based on nutritional, not taxonomic, considerations. It is in the public interest to promote consumption of whole seeds…all whole seeds… versus refined or otherwise fractionated seeds.                                                               [line space]
  3. Exactly what constitutes a “whole grain” will have enormous implications for food formulation: for example, one proposed definition of a whole-grain food claim would mandate that a minimum of 8 grams per 15-gram serving (dry breakfast cereals) or 30-gram serving (cookies) be in the form of “whole grains”. If this definition is limited to cereals and “pseudocereals” (which also remain undefined) and allowing for other necessary “functional” ingredients in the formulation, this leaves precious little room for the use of other whole-seed ingredients such as flaxseed, sesame, pulse or even whole nut powders, in the formulation. Yet all of these non-cereal “whole seeds” generally contribute considerably more nutritional value to foods per unit weight than do cereals, as the recent upsurge in the use of such ingredients in gluten-free foods has demonstrated.                                                [line space]

As of now, there have been precious few letters submitted on behalf of a whole –grain definition that includes non-cereal seed ingredients. The flaxseed industry associations (Ameriflax, Flax Canada and Northern Crops Institute) are the only exceptions. Only ADM has submitted a letter supporting the inclusion of pulses, a fast-growing and nutritionally rich category, within whole grain definitions. From suppliers of sesame seeds, nutmeats, chia and others….nary a peep!

The gluten-free industry should especially be interested in expanding the definition of whole grains to all seeds, given the use of such whole seed ingredients as flaxseed, pea, bean and nutmeat flours as alternatives to gluten-containing wheat and barley cereal grains.

A list of letters already submitted can be found here:

http://www.fda.gov/ohrms/dockets/dockets/06d0066/06d0066.htm

 The ADM letter in support of designating pulses as “whole seeds” can be found here:

 http://www.fda.gov/ohrms/dockets/dockets/06d0066/06d-0066-c000012-01-vol1.pdf

To those industries, associations and individuals that do have an interest in broadening the definition of “whole seed”, there is still time to make your voices heard to the benefit of improving nutrition, enhancing the public welfare and stimulating product innovation.

Please send your letters to:

Division of Docket Management (HFA-305)                                                                   Food & Drug Administration                                                                                         5630 Fishers Lane – Room 1061                                                                                 Rockville, MD  20852

Re.  Federal Register Vol. 71 No. 33: Docket 2006D-0066

For link to December 6, 2013 FoodNavigator-USA Summary of the issue:

http://www.foodnavigator-usa.com/content/view/print/854110 

2 thoughts on “U.S. “Whole Seed” versus “Whole Grain” Labeling Alert

  1. The crux of this argument is a softer version of the adage “Live by the sword, die by the sword.” That is, if the purpose of designating products as having meet a “whole grain” criteria is to inform consumers that the foods have a better nutritional profile due to the presence of “whole [plant/seed] food,” then a broader range of other seed products should also be included as a whole grain.

  2. While this debate is very interesting, it is also intriguing as to why the definition hasn’t been more refined and the federal govt. has actually put a finishing touch to this issue. Claudia, I liked your comment.

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