Submission Number: 07695
Received: 7/14/2011 8:04:49 AM
Agency: Federal Trade Commission
Initiative: Preliminary Proposed Nutrition Principles to Guide Industry Self-Regulatory Efforts; Project No. P094513
Attachments: No Attachments
Dear Chairman Leibowitz,
I am writing to express my opposition to the Preliminary Proposed Nutrition Principles to Food Marketed to Children by the Interagency Working Group (IWG), and strongly urge the withdrawal of these marketing restrictions.
The 2009 Omnibus Appropriations Act directed the FTC, USDA, FDA, and CDC to complete a study and provide recommendations to Congress. Instead, the IWG has proposed marketing restrictions of many healthy foods, including most soups, cereals, breads, and cheese. The IWG’s standards are more restrictive than the standards for foods sold under the school lunch program, the WIC program, and contradict the Administration’s own food recommendations to Americans.
The IWG should withdraw proposed food marketing restrictions and should instead complete a study and report to Congress, as Congress originally intended in the 2009 legislation. In particular, the IWG should base their study and report on peer-reviewed science and a careful consideration of benefits and costs.
Before standards such as those proposed by the IWG are considered, it should be established through peer-reviewed scientific analysis that products subjected to such standards do in fact cause obesity and that the standards, if implemented, would create the desired result of a substantial decrease in obesity.