Friday, May 6, 2011

FDA Label Requirments Can Cause Confusion with Yes! To Cookies All Natural, Gluten Free, Starch Free, Sugar Free Cookies


I just received the Ginger Spice cookies, which are very yummy.  I do have a question about the nutritional info listed on the label.  Something is amiss.

If you have 4 grams of fat (36 calories), 1 gram of protein (9 calories) and 10 carbs (40 calories), the total calories per cookie should be 85.

Is there a mistake on the label?

Thank you,

Dawn Gould

PS  It's nice to find a sugar free, gluten free treat!  Thanks!

Dear Dawn,

Thank you for your kind note.  I'm thrilled that you like the Old Fashioned Ginger Spice Cookies.  I can appreciate your confusion over the label.  The label is correct.  The problem is actually with the current FDA nutrition facts label requirements. Traditional FDA labeling requirements are inadequate and frustrating for new generation products such as Yes! To Cookies.  Nobody else is making a baked food with carbohydrates that are entirely not digested into food energy.  There are many areas where traditional labels fall short.  Some companies even use these holes in traditional nutritional facts to misrepresent the health benefits of a product.  Take for example “sugar free” used on so many products.  What this actually means is that the product is free of sucrose but still can contain many ingredients that metabolize equivalent to sucrose.  The current labeling practice is built around the idea that there are 3 categories of food that convert to energy and provide nutrition when eaten.  These categories are protein, fat and carbohydrates.  A great deal of focus has been placed on the fat in food.  Saturated, unsaturated and other kinds of fats are broken out from total fat so that you can see how much of each kind of fat is present. However there is a great deal of confusion about carbohydrates.  Carbohydrates are determined by subtracting the protein and fat from a total serving of food. Everything that remains is considered a carbohydrate.  We’ve been taught that carbohydrates, with the exception of sugar are healthy and necessary.  This is an arbitrary assessment since all digestible carbohydrates contain the same food energy of 4 calories per gram with the exception of insoluble fiber that isn’t digested so has 0 calories of food energy and soluble fiber that has 4 calories per gram but isn’t digested to glucose so it has no effect on blood sugar and so is not absorbed as energy but rather as fatty acid.  Sugar alcohols are also carbohydrates and generally considered to have half the food energy of sugar so are 2 calories per gram with the exception of erythritol that is actually only 5% digested so is considered to be 0 calories per gram like fiber.  On the label, total carbohydrates are broken down into sugar (sucrose), fiber, sugar alcohols and remaining carbohydrates (that magically transform into being healthy since their not sucrose and called sugar even though the effect the body in the same way as sugar).  What is not explained is how these carbohydrates affect the human body such as are they quickly metabolized or more slowly i.e. glycemic index and how much is converted into food energy and at what rate this food energy is absorbed.  Protein and carbohydrates are accepted to have 4 calories per gram of food energy.  Fat is considered to have 8 calories per gram of food energy.  This does not take into consideration the nutritional value of the food.  Realize that this is all about FOOD ENERGY or Calories and not about nutrition. Starch and flour have almost no nutrition unless it’s been artificially added while vegetables have lots of nutrients.  Fruit and milk have nutrients but contain massive amounts of quickly absorbed carbohydrates that rapidly metabolize to sugar in the body with the same harmful effects as eating sucrose table sugar.   In other words if you have a sandwich with 8 grams of protein it will have 32 calories from protein. If the sandwich has 6 grams of fat, it will have 48 calories from fat.  If your sandwich has 40 grams of carbohydrate it is considered to have 160 calories from carbohydrates with the exception of insoluble fiber (I’ll get back to this). Under the total carbohydrates you’ll find grams of sugar listed as well as grams of fiber.  Occasionally you’ll also see grams of sugar alcohol listed. So using our example of a sandwich you might find 40 total grams of carbohydrate of which 5 are listed as sugar and 2 are listed as fiber, which leaves 33 total carbohydrates that are not sugar or fiber.  What are these carbohydrates?  We know from popular media that sugar is considered evil.  We’ve all been told that fiber is healthy for us and that many of us do not eat enough fiber.  What about the other 33 carbohydrates?  We know that these 33 carbohydrates are still 4 calories per gram or a total of 132 calories of food energy just like sugar and require the same amount of insulin to convert into energy or to be stored as fat.  The 2 grams of soluble fiber will digest to 8 grams of healthy fatty acid to feed the good bacteria in our digestive track.  If the remaining carbohydrates are insoluble fiber, they will pass harmlessly through our digestive track without being converted to food energy.  A good example of this is celery that is mostly cellulose fiber.  As human beings, we simply don’t have the right enzymes in our body to break down and convert insoluble fiber to food energy, so it has no calories.  Since labels are not required to show insoluble fiber since it isn’t digested, some of the carbohydrates may be insoluble fiber. In the Yes! To Cookies original label the company that provided our nutritional facts panel didn’t list insoluble fiber so we were left with a mysterious 3 grams of unexplained carbohydrates in a product that we claim has no digestible carbohydrates.  Later we corrected this inaccuracy by revising our nutritional facts panel to show the insoluble fiber as well as soluble fiber so that now instead of showing 3 grams of fiber we now show 6 grams of fiber. Since only the soluble fiber is actually absorbed and converted to fatty acid and but not to glucose (sugar) we show the calories from the soluble fiber but since there are no calories from insoluble fiber we don’t show the calories from the 3 grams of insoluble fiber.  Sugar alcohols are another difficult topic when it comes to understanding the carbohydrates shown on a food label.  The conventional rule of thumb is that sugar alcohols are 2 calories per gram instead of 4 calories per gram of other digestible carbohydrates such as starch, flour, sugar, fructose fruit sugar, etc.   In other words sugar alcohols are considered to be 50% digested to glucose (sugar).  The FDA gives us the option to name the sugar alcohol used instead of the more vague designation of sugar alcohols if only a single sugar alcohol is used.  In Yes! To Cookies we only use erythritol which is categorized as a sugar alcohol but erythritol is the only sugar alcohol that is 95% not digested or in other words only 5% instead of 50% is digested to glucose (sugar).  What this means is that the erythritol listed is considered calorie free since only 5% or barely a trace amount digests to glucose.  This is such a small amount that it has no significant impact on blood sugar and doesn’t contribute calories. So of the 4 grams of erythritol in Yes! To Cookies less than 1 calorie is digested.  On our original label we listed erythritol as sugar alcohol but we became startlingly aware that many people were considering the sugar alcohol to be 2 calories per gram or 50% digested to glucose like maltitol, xylitol, sorbitol, etc.  We changed to listing erythritol on the new labels to more accurately show the unique benefit of the erythritol we use over traditional sugar alcohols used in other products.  Erythritol is very different from every other sugar alcohol.  Unfortunately, even though erythritol has been available for use as an all-natural sweetener in foods for nearly 30 years, many dietitians and doctors as well as consumers are not familiar with this alternative sweetener.  Recently several new products such as Truvia have entered the market using erythritol as a safe zero calorie sweetener and we anticipate seeing far more as blood sugar management and weight loss continue to become an ever more urgent issue.  So of the 10 grams of total carbohydrates in a serving of Yes! To Cookies, 3 grams are soluble fiber that contributes 12 calories, 3 grams are insoluble fiber that the body can’t absorb and so don’t contribute any calories and 4 grams of erythritol are 95% not digested so contribute less than 1 calorie.  So instead of 10 grams of total carbohydrates contributing 40 calories, the carbohydrates in Yes! To Cookies only contribute 12 calories. The 12 calories of carbohydrates in Yes! To Cookies are not digested into glucose (sugar) so do not impact blood sugar. So the total calories for Yes! To Cookies are for 4 grams of fat you have 32 calories plus 12 calories from the soluble fiber plus 4 calories for the 1 gram of protein for a total of 45 calories.  Our label still shows 60 calories so obviously the company that manufactures our labels to FDA guidelines are still miscalculating something but it’s better to show extra calories based on the FDA’s guidelines even though inaccurate than to make them angry.  My advice is to always read the ingredients and spend time to learn what each ingredient does in your body.  Most of the ingredients, even the strange sounding ones can be searched on the Internet and quickly identified as a problem or harmless.  You’ll notice that Yes! To Cookies ingredients are very few and all natural. 

No comments:

Post a Comment