The Sugar Association Responds to 2015 Dietary Guidelines Advisory Committee Report

‘Added sugars’ recommendations not based on preponderance of science as required by law

The Sugar Association is troubled by the lack of consistency in the scientific process and quality of evidence used by the 2015 Dietary Guidelines Advisory Committee (Committee) as the basis for its Advisory Report to the Secretaries of Health and Human Services and the U.S. Department of Agriculture.

The Committee’s conclusions on “added sugars” intake are not based on the established evidence-based review process of the full body of science, which raises serious concerns the Committee bypassed this process and hand-picked science to support their pre-determined conclusions. Such an approach suggests that these conclusions were “opinion-based” and not “science-based.”

We strongly contend that leading the American public to believe there is an association between a dietary component and detrimental health outcomes requires a robust review of the entire body of high-quality scientific literature by experts in the field of investigation, not a few hand-picked reviews selected by scientists without carbohydrate or “sugars” expertise.

As cholesterol is getting a pass, it is clear that “added sugars” is the newest dietary target, with over 300 mentions in this report. The 2015 Committee, despite weak science, is now telling the American public that many of our health woes are caused by “added sugars” intake. As Dr. F. Edward Scarborough, former director of FDA’s Office of Food Labeling, so aptly stated in his comment regarding “added sugars” submitted to FDA on its proposed changes to the Nutrition Facts Panel:

“There appears to be an underlying assumption that if we can just eliminate the chemical of the decade from the food supply our public health problems will be solved. This intense focus on a single component of the food supply tends to diminish the appropriate focus on the total diet and moderation in consumption.”

We question the usefulness of a Dietary Guidelines process that continues to provide contradictory advice and ultimately confuses the American public. The Sugar Association will ask the Secretaries to maintain the integrity of the Dietary Guidelines for Americans process when the Departments write the final 2015 Dietary Guidelines. We ask that the Secretaries ensure the Guidelines are based solely on the preponderance of scientific information as mandated by Public Law 101.445, not hypotheticals, agendas, opinions or beliefs.

We maintain that all-natural sugar is an important ingredient that has been safely used for thousands of years. Sugar consumed in moderation – a level between restriction and indulgence – is an important part of a healthy diet and active lifestyle.