What is not complete nutritionally in 1.5

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Some good info there

They’re not. They get powdered vitamins/minerals from commercial suppliers of them.

The levels for things like manganese are primarily because they occur naturally in ingredients such as oat flour - but the organically-bound manganese in oat flour has very low bioavailability, so the minerals added contain a tiny amount of manganese, as well.

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Source?

Source?

It’s really a moot point. Even if the “organically-bound” manganese has no bioavailability, it’s still a violation of United States federal law (Title 21 Code of Federal Regulations) to not include the amount in the Nutrition Facts.

Are you sure about that?

Here is the nutrition label for Bob’s Red Mill Oat Flour, which contains manganese:

http://www.quitehealthy.com/nutrition-facts/food-labels/labelL124711.gif

Here is the nutrition label for NutriBiotic rice protein, also containing manganese:

As you can see, this is total anarchy.

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Since you’re reading CFR, see 21CFR101.9(a), 21CFR101.9©, and 21CFR101.9©(8)(ii). If advertising or product literature provides information connecting the nutrients to the food, the so-called “voluntary nutrients”, such as Mn, must be added to the Nutrition Facts. Besides, it’s just common sense that if there’s 695% of Mn in the formulation, you can’t just arbitrarily reduce it to 100% on the Nutrition Facts.

To add to Spiff’s post… RL adds about 2 mg of supplemental manganese, to meet the daily requirement. This makes it an ingredient. As an ingredient, it must be listed, and it must be included in the Nutrition Facts with a DV. … But when it’s listed, they can’t show just the added manganese, they must show the total amount in the product, including the organically-bound fraction. Hence the high number.

I haven’t had luck researching exactly what fraction of the organically - bound fraction is bioavailable. (It’s eady to confirm that is largely unavailable, but I can’t find detail, and most references are to texts not really found online.)

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…because 11.89 mg in the rest of the recipe is 100% not bioavailable?!

As an ingredient, it must be listed, and it must be included in the Nutrition Facts with a DV.

What about the 11.89 mg in the rest of the recipe. It doesn’t need to be listed? Please explain.

[quote=“nutrisludge, post:27, topic:21970”]

First, source your own claim that Rosa Labs grinds up pills for the product they sell. As you look for it, you’ll find out that they use a powder. (Note: I don’t mean what Rob might have blogged he was doing in his self-experiments two years ago, I’m talking about the stuff that actually goes into the product they sell now.)

[quote=“nutrisludge, post:27, topic:21970”]

Wow. You really like throwing the “source” challenge around. This is shown in the detailed nutrition info published by RL, which has already been linked in the thread you’re reading, so just scroll up, follow the links, and read. You’ll see that in Soylent Version 1.5, 11.7 mg of manganese come from the rice protein and the oat flour, while 2.19 mg come from the vitamin/mineral blend.

Your source?

I’m kidding. I don’t want to send you on a wild goosechase, since that’s actually actually incorrect. Most of the micronutrients possible on a DV label are not required at all, as long as they’re not added as separate ingredients. In fact, only four of them are actually required - A, C, calcium, and iron.

Source? Title 21, US Code of Federal Regulations, Secion 101.9 - NUTRITION LABELING OF FOOD. Enjoy.

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I’ve searched thoroughly and can find no paragraph in Section 101.9 that requires naturally occurring manganese to be declared, even if the product contains supplemental manganese. 21CFR101.9©(8)(ii)(B) states that naturally occurring vitamins or minerals MAY be declared, but are not explicitly required to be.

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First, source your own claim that Rosa Labs grinds up pills for the product they sell. As you look for it, you’ll find out that they use a powder. (Note: I don’t mean what Rob might have blogged he was doing in his self-experiments two years ago, I’m talking about the stuff that actually goes into the product they sell now.)

I was merely speculating about the ground-up MVM. To me, it was the only logical explanation for adding 2 mg of Mn to a formula which already contained almost 12 mg of Mn. You seemed to be very sure that all of the micronutrients are added a la carte and I was interested to see the source material.

but the organically-bound manganese in oat flour has very low bioavailability,

I was also looking for your source for this information.

Your source?

I’m kidding. I don’t want to send you on a wild goose chase, since that’s actually actually incorrect. Most of the micronutrients possible on a DV label are not required at all, as long as they’re not added as separate ingredients. In fact, only four of them are actually required - A, C, calcium, and iron.

Source? Title 21, US Code of Federal Regulations, Secion 101.9 - NUTRITION LABELING OF FOOD. Enjoy.

If advertising or product literature provides information connecting the nutrients to the food, the so-called “voluntary nutrients”, such as Mn, must be added to the Nutrition Facts. Enjoy.

I wonder how low the bio-availability of organically bound Mn in rice protein/(starch)? and in oat flour is?

Please cite and quote where it says this.

p. 27, N5

In any case, since Rosa Labs lists the so-called “voluntary nutrients” on Soylent’s nutrition label, they are legally required to provide accurate information, which they have not done.

“When must voluntary nutrients be listed?
Answer: In addition to the nutrients shown on the sample labels in this
guidance, other nutrients (listed in FDA’s regulations, e.g., thiamin) must be
included in a food’s Nutrition Facts label if the nutrients are added as a
nutrient supplement to the food, if the label makes a nutrition claim (such as a
NCC) about them, or if advertising or product literature provides information
connecting the nutrients to the food. 21 CFR 101.9(a), 21 CFR 101.9©,
21 CFR 101.9©(8)(ii)”

I personally am not sure this part means that they have to list the naturally occurring manganese, which isn’t a “nutrient supplement to the food”.

Regardless I do agree they should list it…

Does the Daily Value take bioavailability into consideration normally?

The manganese content has to be listed because, “advertising or product literature provides information connecting the nutrients to the food.” (See, e.g., https://www.soylent.com/, “What is Soylent Made Of?”) The “why” is immaterial in this case. Rosa Labs has listed Mn on their nutrition label, for whatever reason. Therefore, they are obliged to provide accurate information, which they have not done.

The Daily Value does not consider bioavailability.

It is interesting to me that not only 1.5’s manganese levels exceed the Institute of Medicine’s (IOM) Tolerable Upper Limit (TUL) but also its magnesium (Mg) amount. The TUL for Mg is 350 mg/day. 1.5 contains 475.96 mg of Mg. However, the IOM has a footnote which states, “The ULs for magnesium represent intake from a pharmacological agent only and do not include intake from food and water.” There is no such footnote for Mn. It could be implied that the IOM feels that Mg is not highly bioavailable in food but Mn is.

I didn’t say they were a la carte. You said they were grinding pills, like amateurs, I replied that they were buying powder from a commercial supplier, like a food company. They’ve previously shared they use a powdered vitamin/mineral blend from a supplier. Typically, you’d have control over some, but not all, elements of such a blend, unless you want to pay a lot for customization.

It says no such thing, there. You’re confusing “providing information” and making a “nutrient claim.” Making a “nutrient claim” is what matters, and the FDA is very clear about what that means.

For example, if your milk is called “Vitamin D Milk,” or says on the label that it’s a “good source of vitamin D,” or says it’s “fortified with vitamin D,” then it must also show the vitamin D content of the milk, like so:

(Incidentally, anyone who has never looked at the Amazon reviews for Tuscan Whole Milk is really missing out.)

You can see a good breakdown of exactly what constitutes a nutritient claim in the FDA guidance document, Guidance for Industry: A Food Labeling Guide (10. Appendix B: Additional Requirements for Nutrient Content Claims). It’s a very clear one-page which explicitly shows what language constitutes a claim, and what levels must be met when making such a claim.

This is all fairly moot, though, because the Soylent boxes, bags, and primary adverts are fairly careful about making nutritient claims - in the sense of not making any. Providing additional info, and putting optional info a a DV label, does not constitute a nutrient claim.

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You can imply all day long, it still isn’t explicit. You have yet to prove that RL is non-compliant.

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Thank you for that information.

You need to read the whole sentence:

“N5. When must voluntary nutrients be listed? Answer: In addition to the nutrients shown on the sample labels in this guidance, other nutrients (listed in FDA’s regulations, e.g., thiamin) must be included in a food’s Nutrition Facts label if the nutrients are added as a nutrient supplement to the food, if the label makes a nutrition claim (such as a NCC) about them, ***or if advertising or product literature provides information connecting the nutrients to the food.***”

(See, e.g., https://www.soylent.com/, “What is Soylent Made Of?”)

Go take a look at how the FDA specifies how the amount to be listed is determined, and get back to us.

You’ll find they do not specify how you should determine the amount you list. If they test your product, however, you will be non-compliant if their lab results don’t match your claim. So the only real question is this: given the lab test used for manganese, what level does RL expect will come up in the test?

That being said, I don’t know if RL had such analyses done, or whether they used database estimates, or what. I don’t recall seeing them state their methodology on this.

The “advertising or product literature” you’re referring to is an excerpt of the Nutrition Facts label. So, you’re basically saying that Soylent is forced to list the manganese content on the label because they list the manganese content on the label.

That sounds a bit goofy, to me. Does it not sound goofy, to you?

Please, go and read the guidance page I linked above. It shows very specifically what exact words constitute nutrient claims.

The truth is simply that they must list the manganese content on the DV label because manganese is listed on the bag as an ingredient:

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