Submission Number: 00029
Received: 5/5/2011 8:57:48 AM
Commenter: Laura Argo
Organization: Real Food for Real Kids
State: Outside the United States
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
Please clearly define "meaningful contribution" in the statement: "Foods marketed to children must make a meaningful contribution to healthful diets, and contain at least one of the healthy food groups: fruits & veggies, whole grains, low fat or fat free dairy, fish, extra lean meat, eggs, nuts & seeds, beans."
This appears to be very lose criteria for assessing the nutritional value of a given food.
FOr example, fruit leathers (i.e. roll ups) could be considered acceptable for marketing to children as they contain some fruit and no trans fat (or any fat at all). They also contain sugar and artificial dyes. Regardless of these latter additions, they do not contribute meaningfully to a healthy diet. The human body has no need for this food or the negligible vitamin and mineral content it may (or may not) contain. One is much better off eating a real piece of whole fruit.
The term "meaningful" requires more specific definition for these regulatory efforts to be successful. General, vague quantifiers will leave too much room for interpretation and subjectivity.
This proposal is a great step in the right direction, however, it is important to make it right the first time, so that the goal of reducing junk food marketing to children is truly achieved.