Should the Food and Drug Administration mandate the listing of added sugars on the Nutrition Facts Panel? That is the question that brought on a bundle of polarized public comments.

The American Heart Association, the American Dental Association and the Center for Science in the Public Interest all foresee the F.D.A.’s proposal resulting in a more informed public and possible health benefits. In contrast, a survey from the International Food Information Council Foundation shows the listing may result in consumer confusion. The American Bakers Association, the Retail Bakers of America and the Sugar Association all oppose the listing.

The F.D.A. proposed major changes to the Nutrition Facts Panel, including the added sugars listing, in the March 3 Federal Register. The F.D.A proposed the definition of added sugars as sugars and syrups added to foods during processing or preparation. The deadline to send public comments to the F.D.A. was Aug. 1.

The IFIC Foundation, based in Washington, included preliminary survey research in its comments. The IFIC Foundation commissioned Turner Research Network, a marketing research consulting firm in Dunwoody, Ga., to conduct a national on-line survey in June and July that involved 1,088 people.

The people were exposed to three Nutrition Facts Panels: the current one with only a “sugars” listing; the one proposed by the F.D.A. with a “sugars” listing and an “added sugars” listing; and one with a “total sugars” listing and an “added sugars” listing.

When asked to give the total amount of sugar in the product after looking at each panel, 92% who viewed the first one with only “sugars” gave the correct answer. The percentages fell to 55% for the one with “sugars” and “added sugars” and 66% for the one with “total sugars” and “added sugars.”

When viewing the “sugars” and “added sugars” Nutrition Facts Panel, 52% said they believed the added sugars are added to the amount in the sugars listing, which is incorrect. When viewing the “total sugars” and “added sugars” Nutrition Facts Panel, 33% said they believed the added sugars was added to the amount in the total sugars listing.

People in the survey also had different interpretations on the meaning of added sugars. Thirty-four per cent believe it means more sugar has been added to the products while 28% think the “added sugars” listing distinguishes between added sugars and sugars that are occurring naturally in the other product ingredients. Another 19% said they did not know the meaning of added sugars.

Why it’s a bad idea

The American Bakers Association, Washington, and the Retail Bakers of America, Tinley Park, Ill., combined to send their comments to the F.D.A. They said the listing would convey to the reasonable consumer that added sugars are chemically different from naturally-occurring sugars and/or that added sugars have different health effects than naturally-occurring sugars.

“Thus, it would be false and misleading to imply, as a declaration of added sugars clearly would, that added sugars are distinguishable in any way from any other analytically quantifiable sugars from naturally-occurring sugars or from other sources in the product,” the two baking groups said. “A rule that would compel companies to include false and misleading information on their product labels, or information that sent a message with which they did not agree, would not survive First Amendment scrutiny.”

The A.B.A. and the R.B.A. said it would be challenging, if not impossible, to calculate a reduction in added sugars during the processing of a yeast-leavened product. They also said they believe the F.D.A. does not have the authority to gain access to company records, which may help determine the amount of reduction in added sugars during processing but also might undermine the proprietary nature of food product formulations.

“The ability to retain and claim the proprietary nature of product formulations is essential to staying competitive in the marketplace,” the A.B.A. and the R.B.A. said.

The Sugar Association, Washington, said the term “added sugars” is misleading and without scientific justification. In its comments the association said the F.D.A.’s proposed rule relies too heavily on the 2010 Dietary Guidelines for Americans.

“We have serious concerns that it is a gross expansion of the intent of the law governing the D.G.A. to use selective dietary guidance from a single edition of the D.G.A. to promulgate food labeling regulations,” the Sugar Association said. “We also question whether or not the Dietary Guidelines for Americans is a consensus report and strongly disagree that the 2010 D.G. or the 2010 Dietary Guidelines Advisory Committee report provided ‘conclusive,’  ‘documented’ or ‘strong’ scientific evidence to support the agency contention that ‘added sugars’ labeling is necessary for Americans to ‘maintain healthy dietary practices.’”

Why it’s a good idea

The American Heart Association, Dallas, pointed out it recommends consumers limit intake of added sugars, as does the 2010 Dietary Guidelines for Americans.

“Yet this can be difficult to do when added sugars are not included on the Nutrition Facts label,” the A.H.A. said in its comments. “To identify added sugars, consumers must examine the product’s ingredient list and look for the more than 25 ingredient names that indicate the presence of added sugars. Including added sugars on the Nutrition Facts label will give consumers an easy way to determine the amount of added sugars a product contains. We look forward to seeing this requirement implemented.”

The A.H.A. and the Washington-based Center for Science in the Public Interest both encouraged the F.D.A. to establish a Daily Value for added sugars.

“Without a DV, consumers could only compare the relative amounts of added sugars among products but would not know how much of a day’s worth of added sugars a food contains,” the C.S.P.I. said in its comments.

Added sugars should be expressed in teaspoons as well as grams, the C.S.P.I. said.

“Few Americans are familiar or facile with the metric measure (grams) used for total sugars, but virtually everyone understands household measures (as are used on labels for serving sizes),” the C.S.P.I. said.

Evidence from clinical studies shows added sugars increase markers for cardiovascular disease, diabetes and the metabolic syndrome, according to the C.S.P.I. Added sugars may contribute to non-alcoholic fatty liver disease, according to the C.S.P.I.

The American Dental Association, Chicago, said listing added sugars will help consumers monitor their added sugar intake.

“Combined with a strong platform of nutrition education, these disclosures will empower consumers to become mouth healthy by being food wise,” the dental association said.

The F.D.A. in the March 3 Federal Register cited both an Institute of Medicine report on macronutrients and the 2010 Dietary Guidelines Advisory Committee in giving its reasons for the proposed mandate of added sugars on the Nutrition Facts Panel.

The I.O.M. report said many foods and beverages that are major sources of added sugars have lower micronutrient densities compared to foods and beverages that are major sources of naturally-occurring sugars. The Dietary Guidelines Advisory Committee said reducing the consumption of calories from solid fats and added sugars allows for increased intake of nutrient-dense foods without exceeding overall calorie needs.

The F.D.A. said it proposed the mandatory listing of added sugars for four reasons: the variability in ingredients used; the need for consumers to have a consistent basis on which to compare products; the need for consumers to identify the presence or absence of added sugars; and the need for consumers to identify the amount of added sugars when they are present in a food. The F.D.A. acknowledged the mandatory listing of added sugars would need to be accompanied by consumer education.