The DV for iron is 18mg, which is the amount for menstruating women. Men need 8mg of iron. So for men it is nutritionally complete, and for women, it’s pretty close.
That’s also just the iron they add not the total amount of iron that is in it. Same with the magnesium. Some of the ingredients contain iron and magnesium but Soylent, and every other food manufacturers, aren’t required to report those values. They are only required to report the amounts of vitamins and minerals they add to the mix and a few key nutrients. There was a much more detailed spreadsheet floating around a while back that showed everything. I have since lost the file otherwise I would post it myself.
Spreadsheet is available here: https://faq.soylent.com/hc/en-us/article_attachments/202548035/Soylent_1.5_Formula.xlsx
@horsfield I’m pretty sure that the iron reported for Soylent 1.5 comes from the rice protein and oat flour, and that they don’t add any supplemental iron (as you can see here). This is why the amount is not a precise 25% DV per serving.
Is this true? I’d be interested in seeing a source for this if you have one. My understanding is that if a vitamin or mineral is specifically added, then the total amount (including the amount from other ingredients) must be reported on the label.
There was a big long flame war of a thread a while back started by @nutrisludge about the amount of manganese in Soylent. The gist of it was that the nutritional label said one thing and the spreadsheet I mentioned said another. Many people dug through the FDAs guidelines trying to prove some sort of deception on the part of RL. In the end all they ended up proving is that RL was only required to report the amounts they added and could report the total if they felt like it. FWIW I believe for specific micronutrients like iron they had to report the full amount. I don’t remember exactly.
Yeah, I remember that thread well:
I reread the whole thread and don’t see anyone saying this though:
As far as I can tell, the conclusion is that RL was not quite following the letter of the law, but that enforcement is likely to be nonexistent, so they can get away with it.
Finally found the spreadsheet I was looking for. 1.5 has 15.47mg of iron per bag.
Nope. The discussion was spread across two threads and it was brought up in the manganese thread days after it was discussed in the other thread. This is the thread that contains the relevant text from the FDA:
CFR - Code of Federal Regulations Title 21
(ii) The declaration of vitamins and minerals as a percent of the RDI shall include vitamin A, vitamin C, calcium, and iron, in that order, and shall include any of the other vitamins and minerals listed in paragraph ©(8)(iv) of this section when they are added as a nutrient supplement, or when a claim is made about them. Other vitamins and minerals need not be declared if neither the nutrient nor the component is otherwise referred to on the label or in labeling or advertising and the vitamins and minerals are:
You need to read more for context, but I’ve said more than I ever cared to in the original thread.
I’m familiar with this regulation, and my interpretation is that if a vitamin or mineral is specifically added, then the total amount (including the amount from other ingredients) must be reported on the label. This is also what @MentalNomad says in the thread you linked to. @Syke also expresses this same view.
I understand that you disagree. It seems that there are multiple ways to interpret “when they are added as a nutrient supplement”.
I interpret it as “when some manganese is added as a supplement, all manganese must be declared”.
You interpret it as “when some manganese is added as a supplement, that supplemental manganese must be declared”.
In the end though, the FDA is likely to be care more about overstated nutrient values than understated, since there’s always some degree of understatement of values to account for gradual degradation over time.
This is legal text. They wrote exactly what they meant (or they made a mistake, but the current version of the text remains identical). Requirement and exceptions are made explicit, if you read the entire document:
The declaration may also include any of the other vitamins and minerals listed in paragraph ©(8)(iv) of this section when they are naturally occurring in the food.
The word may means the declaration is voluntary, not required. It would say must (or, historically, shall) if it was a requirement.
Nowhere does it say that if a vitamin or mineral is added, you must also include the naturally occurring vitamins or minerals on the label, and the text is mind-numbingly precise. For example:
(e) If a food is modified by incorporating air (aerated), and thereby the density of the food is lowered by 25 percent or more in weight than that of an appropriate reference regular food as described in §101.13(j)(1)(ii)(A), and the reference amount of the regular food is in grams, the manufacturer may determine the reference amount of the aerated food by adjusting for the difference in density of the aerated food relative to the density of the appropriate reference food provided that the manufacturer will show FDA detailed protocol and records of all data that were used to determine the density-adjusted reference amount for the aerated food. The reference amount for the aerated food shall be rounded to the nearest 5-g increment. Such products shall bear a descriptive term indicating that extra air has been incorporated (e.g., whipped, aerated). The density-adjusted reference amounts described in paragraph (b) of this section may not be used for cakes except for cheese cake. The differences in the densities of different types of cakes having different degrees of air incorporation have already been taken into consideration in determining the reference amounts for cakes in §101.12(b). In determining the difference in density of the aerated and the regular food, the manufacturer shall adhere to the following:
I concede if we were voting on the question, I would be in the minority. That doesn’t mean I’m wrong.
@wezaleff Thank you for clearing this up. A Ctrl-F on “naturally occurring” on the eCFR page that you linked to has persuaded me that you are correct, and that my earlier interpretation was incorrect.
However, I’m still a little unsure about the exact meaning of this section, given the highlighted phrases:
(3) Two classes of nutrients are defined for purposes of compliance:
(i) Class I. Added nutrients in fortified or fabricated foods; and
(ii) Class II. Naturally occurring (indigenous) nutrients. If any ingredient which contains a naturally occurring (indigenous) nutrient is added to a food, the total amount of such nutrient in the final food product is subject to class II requirements unless the same nutrient is also added.
(4) A food with a label declaration of a vitamin, mineral, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated or monounsaturated fat, or potassium shall be deemed to be misbranded under section 403(a) of the Federal Food, Drug, and Cosmetic Act (the act) unless it meets the following requirements:
(i) Class I vitamin, mineral, protein, dietary fiber, or potassium. The nutrient content of the composite is at least equal to the value for that nutrient declared on the label.
(ii) Class II vitamin, mineral, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated or monounsaturated fat, or potassium. The nutrient content of the composite is at least equal to 80 percent of the value for that nutrient declared on the label. Provided, That no regulatory action will be based on a determination of a nutrient value that falls below this level by a factor less than the variability generally recognized for the analytical method used in that food at the level involved.
(5) A food with a label declaration of calories, sugars, total fat, saturated fat, trans fat, cholesterol, or sodium shall be deemed to be misbranded under section 403(a) of the act if the nutrient content of the composite is greater than 20 percent in excess of the value for that nutrient declared on the label. Provided, That no regulatory action will be based on a determination of a nutrient value that falls above this level by a factor less than the variability generally recognized for the analytical method used in that food at the level involved.
(6) Reasonable excesses of a vitamin, mineral, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated or monounsaturated fat, or potassium over labeled amounts are acceptable within current good manufacturing practice. Reasonable deficiencies of calories, sugars, total fat, saturated fat, trans fat, cholesterol, or sodium under labeled amounts are acceptable within current good manufacturing practice.
Is it simply saying that added nutrients (eg, manganese sulfate) are considered Class I and naturally occurring nutrients (manganese in the rice protein) are considered Class II even when some of those same nutrients (manganese) are Class I? Or is it saying something else?
The easiest way to think about class I/II is that class I is the stricter of the two requirements: at least 100% of the label claim for class I vs. at least 80% for class II.
The manganese in rice would be class II, but when you add manganese sulfate you’ve then triggered class I compliance, which means the total value has to be at least 100% of the label claim (rather than 80% for class II) for that nutrient.
There are stricter limits for certain label claims (a limit of 20% in excess of the label value for “calories, sugars, total fat, saturated fat, trans fat, cholesterol, or sodium”). And as you highlighted, a “reasonable” excess is otherwise allowed, which is at the FDA’s discretion (so basically undefined in the text).
It is saying that if you add manganese sulfate, and you don’t want to be declared “out of compliance” when they test your product, then you must meet the strict rule where you product actually contains 100% of the amount you say on the label.
Then it says that if you merely have naturally occurring manganese in the product, and you don’t want to be declared “out of compliance” when they test you, then you merely need to have 80% of the amount you claim on the label… unless you ALSO included manganese sulfate, in which case you got back to the stricter 100% rule.
Which basically agrees with what wezaleff said.
However, I’ll note that this discussion and the quoted rules are only about compliance - it does not actually say what levels should be listed. It just says that if they test and you’re lower than you put on the label, you’re out of compliance.
If you read all of the document and the referenced documents on testing and sampling, they indicate that for a nutrient that is being listed on the label, you should be making the best effort to list the amount actually in the total composite product. I have yet to find a specific line that says this is a requirement, and it seems that under-reporting is acceptable as long as you do not exceed the vague reference to “reasonable excesses.”
So, summing up into plain English:
- If you include an element or vitamin as a supplement, you gotta list that item.
- They say (elsewhere) that you should try to list approximately the total amount actually in the composite product.
- Since it’s a supplement, when they actually test the product, you better have at least 100% much as you list.
- You can have a little more than you list, but only as long as it’s “reasonable.”
Adding these up, you can infer that you need to include the naturally-occurring part when you list it, or else you run the risk that when they test your product, and the amount comes in way higher than the amount you list they may say your excess is “not reasonable.”
Frustratingly, this means manufacturers must also be careful about which assays the FDA uses when testing… because if the given assay will detect one form and not another, you need to know that to determine how much to put on your label! For (hypothetical) example, if the given assay would detect both manganese sulfate and the naturally-occurring organically bound manganese, the label should show the total of both. But if they’re using an assay which would only detect the manganese sulfate and would not detect the organically-bound stuff, then you should only include the amount from the manganese sulfate on the label - or else, when they test, they’ll find you out of compliance!
But 15.47 isn’t 100% of the FDA. 18mg is!
And where did I say it was???
You didn’t, I was just confused. Cheers!
This is a very enlightening comment, @axcho - any chance you’d be willing to make it a full-fledged page/post somewhere else that you fleshed out and kept maintained? This comment is great, but it’d be great to have something of a canonical source to help point people to for clarification on these terms.
I actually ran across this comment while trying to better understand the terms myself, as Soylent targets being 100% of the DV, but Joylent targets 100% of RDI. Since they’re based in Amsterdam, I’m guessing their RDI is different than whatever constitutes the RDI for the US/FDA, but I’m not sure.
In any case, the raw values end up being pretty significantly different in many cases, so better understanding why that’s the case should help people in understanding the values that are right for them.
The IOM guidelines are valuable to know, but it makes me wonder what the EU equivalent would be and how much difference/variance there is between them. Is there something out there that’s close to a canonical international source for recommended micronutrient intake?
Yes, I would love to do this in the near-ish future. We are going back and forth with some manufacturers on our custom vitamin premix, so I’ll definitely want to have that out as a blog post or something before (or at least at the same time as) we announce the new vitamins. I’m looking forward to showing off what we’ve got in store.
The EU one is quite different. US recommended FDA amounts of Vitamin A are like 5 times the amount of the UK. And Biotin is like 10 times. Not sure how they can be so different.