We appreciate the work of the 2015 U.S. Dietary Guidelines Advisory Committee, and agree that total diet and physical activity must be taken into consideration to achieve a healthy lifestyle. However, the Committee’s efforts went beyond its charge and authority to develop dietary recommendations based on scientific evidence by advocating for public policies such as taxes and restrictions on foods and beverages. The Committee does not have the authority to make such recommendations, nor the scientific evidence or expertise to back up its recommendations.
In response to the 2015 U.S. Dietary Guidelines for Americans Advisory Committee report released today, the American Beverage Association issued the following statement:
“We appreciate the work of the 2015 U.S. Dietary Guidelines Advisory Committee, and agree that total diet and physical activity must be taken into consideration to achieve a healthy lifestyle. However, the Committee’s efforts went beyond its charge and authority to develop dietary recommendations based on scientific evidence by advocating for public policies such as taxes and restrictions on foods and beverages. The Committee does not have the authority to make such recommendations, nor the scientific evidence or expertise to back up its recommendations.
When it comes to sugar and sugar-sweetened beverages, the Committee did not consider the body of science. Numerous studies have shown that restricting one food or food group is not the best approach for achieving calorie balance or maintaining a healthy weight. Rather, focusing on an overall approach of reducing calories from all sources while increasing physical activity provides a comprehensive and long-term solution for doing so. As with any other source of calories, sugar-sweetened beverages can be part of an overall diet. Moderation and balance are key.
This Committee also went beyond its scope in examining the safety of low- and no-calorie sweeteners and caffeine, ingredients that have been repeatedly deemed safe by the U.S. Food and Drug Administration for decades.
Moreover, given the importance of the Committee’s guidance on helping Americans control their weight, their lack of support for foods and beverages made with low- and no-calorie sweeteners is contradictory. The body of science clearly shows that these ingredients can be an effective tool in weight loss, weight management and management of health conditions such as diabetes and hypertension.
When it comes to caffeine, the Committee referred to ‘high’ caffeine intake, which lacks scientific definition, and arbitrarily focused on a single category of products – energy drinks.
However, other sources of caffeine, like coffee, contain the same and oftentimes significantly higher amounts of caffeine than energy drinks, and contribute a much larger proportion of caffeine to the American diet. Thus, the Committee’s approach to caffeine is inconsistent and far from scientific.
Our industry strongly believes that the 2015 Dietary Guidelines for Americans should be based on the weight of scientific evidence while also providing real world guidance that is achievable for the majority of Americans. In reviewing the Committee’s recommendations, we encourage the Agencies to seek ways to help Americans achieve balance and moderation in their diet - while also promoting the importance of physical activity, rather than advocating for restricting only specific items and eliminating choice.”
On Industry Leadership:Our industry is committed to helping consumers balance what they eat and drink with what they do. Most recently, in partnership with the Alliance for a Healthier Generation, the industry announced a nationwide initiative to reduce beverage calories consumed per person by 20 percent by 2025. To do so, the beverage companies will leverage their marketing, innovation and distribution strength to increase and sustain consumer interest in and access to beverage options to help consumers reduce calories consumed, such as smaller portion sizes, water and other no- or lower-calorie beverages. This is the single-largest voluntary effort by an industry to help fight obesity. These are efforts that will have real and lasting impact. In addition, the industry has voluntarily reduced calories from its beverages sold in schools by 90 percent through its national School Beverage Guidelines. In support of First Lady Michelle Obama’s “Let’s Move!” campaign, the industry announced its Clear on Calories initiative, voluntarily placing clear calorie labels on the front of every bottle, can and pack they produce. The ABA and its member companies also were part of Mrs. Obama’s launch of “Drink Up!,” the initiative of the Partnership for a Healthier America. When it comes to energy drinks, leading energy drink makers voluntarily place advisory statements on energy drink packaging stating that energy drinks are not recommended for children. They also have voluntarily pledged not to market these products to children or sell them in K-12 schools. These guidelines and more are noted in the ABA Guidance on the Responsible Labeling and Marketing of Energy Drinks.
On Sugars:A 2014 position statement by the Academy of Nutrition and Dietetics concluded that a comprehensive approach to reducing calories from all sources while increasing physical activity is the most effective long-term solution for calorie reduction. This Committee placed a laser-like focus on “added” sugars, suggesting that they are somehow different from those that are naturally occurring. As acknowledged by the U.S. Food and Drug Administration in its preamble to proposed rulemaking on changes to the Nutrition Facts Panel, there is no scientific basis for this assertion and no way of analytically distinguishing between “added” and naturally occurring sugars. Importantly, recent trends show that sugar-sweetened beverage consumption has declined significantly over the past decade. NHANES shows a consistent and progressive reduction in consumption of soda and all sugar-sweetened beverages in all age groups from 1999 to 2010. The steep decline in sugar-sweetened beverage consumption was not accompanied by any change in prevalence of obesity. (Soda consumption was 67 kcal/d lower in youths and 58 kcal/d lower in adults in 2010 compared to 1999.) All common sugars, whether free or intrinsic, are the same when it comes to the amount of calories they contain and the way they are metabolized by the body. The Committee also has suggested a recommendation to limit “added” sugars intake to less than 10 percent of energy. This Committee’s role is to make food-based recommendations based on the totality of the science. The Institute of Medicine (IOM) is the body which sets nutrient thresholds. IOM suggests that “added sugars should comprise no more than 25 percent of total calories consumed.”
On Low- and No-Calorie Sweeteners:The Committee reviewed evidence on the efficacy of low-calorie sweeteners in weight loss and weight management, which has been scientifically supported as recently as last year, and concluded that these ingredients help with weight loss. However, the Committee’s recommendations contradict its conclusion by not recommending beverages that contain no- and low-calorie sweeteners as an effective tool to reduce both sugar and caloric intake. A 2014 survey of National Weight Control Registry members and the CHOICE (Choose Healthy Options Consciously Everyday) randomized control trials (RCT) documented the benefits of low- and no-calorie sweeteners for overall weight management. More recently, a Colorado/Temple study that looked at more than 300 people and was published in the journal Obesity affirmed that diet beverages are an effective tool as part of a weight loss program. Many major health organizations have affirmed the benefits of low- and no-calorie sweeteners in balancing consumers’ carbohydrate and energy intake, including the Academy of Nutrition and Dietetics, the American Heart Association and the American Diabetes Association. Despite the overwhelming body of evidence, the Committee did not recognize the existing research for aspartame safety relative to cancer. The National Cancer Institute of the National Institutes of Health study looked at approximately 500,000 men and women over a five-year period to determine whether an association between aspartame and cancer exists and concluded no increased risk of hematopoietic or brain cancers from aspartame consumption. Additionally, this study concluded that consumption of aspartame-containing beverages did not increase risk of leukemias, lymphomas or brain tumors. More recently, the American Cancer Society looked at intake of low-calorie (including aspartame) or sugar-sweetened carbonated beverages among more than 100,000 adult men and women who provided information on diet and lifestyle over a 10-year period in the Cancer Prevention Study-II Nutrition Cohort and concluded that moderate consumption does not increase risk of non-Hodgkin lymphoma cancer. Yet the Committee’s conclusions are contrary to the evidence cited.
On Caffeine:The appropriate body to look at ingredient safety – including that of caffeine – is the U.S. Food and Drug Administration. Evaluating the safety of caffeine was not only outside of the Committee’s scope of work, but in doing so, they did not have appropriate experts to conduct and appropriate assessment, leading to misinterpretation of the data and conclusions. In reviewing the safety of caffeine, the Committee focused on energy drinks which account for less than 10 percent of total caffeine intake. Importantly, the safe use of caffeine is supported by a long history of use and by extensive clinical and nonclinical studies. Both synthetic and naturally occurring caffeine are identical in chemical structure and effect on the body. Furthermore, the safety of caffeine has been established by health authorities and international organizations worldwide. The Committee’s assessment of caffeine and energy drinks did not appear to evaluate the totality of the evidence. Its conclusions about energy drink safety were based upon what the Committee itself characterized as “limited” evidence, which falls well below the required evidentiary standard for the Dietary Guidelines for Americans. Caffeine amounts vary depending on the beverage type and caffeine source. Most energy drinks contain significantly less caffeine than a similarly-sized coffeehouse coffee. In fact, many contain about half the caffeine. Even so, regardless of source, government data shows that average levels of caffeine consumption for all age groups in the United States are well within recommendations of health authorities. Furthermore, even with the entry of energy drinks into the marketplace, overall caffeine intake has remained stable. This Committee’s recommendations did not scientifically define “high” caffeine intake and inappropriately, narrowly and arbitrarily focused on a single category of products, energy drinks – which often have considerably less caffeine than similarly sized containers of coffee.
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The American Beverage Association is the trade association representing the broad spectrum of companies that manufacture and distribute non-alcoholic beverages in the United States.