I’m sure you understand that a lack of requirement does not imply a prohibition.
Post must be at least 20 characters.
What? Post must be at least 20 characters.
No one said or even implied that.
See above. Post must be at least 20 characters.
Right, no “other” nutrient needs to be listed. Manganese is added as a supplement, therefore the amount of manganese in Soylent must be labelled. That includes the natural amounts and the supplemental amounts because that’s exactly what would show up in testing, which is how the FDA determines compliance with labelling laws.
N25. How do I determine what values to declare on the Nutrition Facts label?
Answer: The nutrient values declared on the Nutrition Facts label are based
on the nutrient profile of the product, as packaged, rounded as required by
regulation. Rounding rules are provided in 21 CFR 101.9© and
summarized in Appendix H.
(Emphasis added above) The value declared must match the profile, which would include natural and supplemental amounts.
The amount added needs to be listed, according to the text I quoted above. The inherent nutrients are still optional (again according to the quoted text).
Can you quote where it says that rather than using your own words? That seems to conflict with what I quoted above from CFR - Code of Federal Regulations Title 21.
So when you read this:
You somehow come to the conclusion that he’s claiming a Nutrition Facts label should be empty if there are no vitamin or mineral supplements:
Your conclusion does not follow. Read CFR - Code of Federal Regulations Title 21. You’re applying one subsection applying to a specific group of nutrients to every nutrient. Different nutrients have different requirements for labeling. Some are required are some are optional. That’s a pretty basic concept that everyone reading this thread should understand by now.
There! You answered your own question.
“Nutrient profile” is not defined as a term explicitly, but the guidelines seem to be using it as shorthand for “the nutrients you must list on the Nutrition Facts label (by regulation).” If there is no applicable regulation requiring a specific nutrient, whether or how you round the value on the Nutrition Facts label is tangential at best.
That PDF is a set of guidelines. I was quoting the actual regulations, which the guidelines reference. That’s the 21 CFR 101.9© bit; that’s what I was quoting from. I don’t see anything in CFR - Code of Federal Regulations Title 21 that supports what you are saying, but I admit I only looked up the sections that appeared relevant.
That PDF is not a list of regulations, as I noted above. That’s why I looked up the references in the first place: 21 CFR 101.9(a), 21 CFR 101.9©, 21 CFR 101.9©(8)(ii). Nothing there supports your statement.
More reading and less typing and you could have found it for yourself:
21 CFR 101.9©(8)(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…
More reading and less typing and you could have found it for yourself:
I actually quoted that above. Keep reading:
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.
As I said above, not required.
@Nutrisludge, you keep highlighting the same line of text over and over again, but all you are really highlighting is your misinterpretation of the verbiage.
@wezaleff, he already ignored that argument the first time I made it. Good try, though.
There’s 11.7 mg of Mn naturally occurring in the food in 1.5, according to RL’s spreadsheet.
That spreadsheet is not an advertisement, nor does it appear on the label.
I’m done. If you think that it’s ok for RL to hide the fact that 1.5 contains more than the Tolerable Upper Limit of Mn, that’s fine with me. I don’t have to live with it.
(g) Compliance with this section shall be determined as follows:
(2) The sample for nutrient analysis shall consist of a composite of 12 subsamples (consumer units), taken 1 from each of 12 different randomly chosen shipping cases, to be representative of a lot. Unless a particular method of analysis is specified in paragraph © of this section, composites shall be analyzed by appropriate methods as given in the “Official Methods of Analysis of the AOAC International,” 15th Ed. (1990), which is incorporated by reference in accordance with 5 U.S.C. 552(a) or 1 CFR part 51 or, if no AOAC method is available or appropriate, by other reliable and appropriate analytical procedures. The availability of this incorporation by reference is given in paragraph ©(7) of this section.
Compliance is determined by analysis. I’m afraid that if Soylent is tested it will be found not in compliance.
Your very reaction to my question proves my point about you being a troll.
The below nutrition label is for Maseca masa harina. As you can see there is no magnesium listed in the nutrition label because it is naturally occurring. That seems to imply that companies are not required by law to list naturally occurring magnesium. Seeing as you or anyone else has yet to prove that naturally occurring nutrients are required by law to be listed even when there is a supplemental ingredient seems to uphold this implication.
RL supplements manganese, mentions it on its website, AND lists it in Soylent’s nutrition label as actually IS required by law. I personally find this to be a rather annoying but understandable loophole in the law.
This is interesting, but the requirements are quite complex.
(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.
This implies that manganese will be a class I nutrient in Soylent. Continuing:
(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.
So an excess of a class I nutrient would be compliant. If it is a class II nutrient, this clause applies:
(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.
Again, Soylent would be compliant if it was a class II nutrient.
Both of these clauses do seem to potentially conflict with a later clause:
(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.
I assume reasonableness is determined by the FDA, in which case they should take bioavailability into account.
I think the intent of this clause is to prevent a company from claiming they are adding 2 mg of something if they are (carelessly?) adding 4 mg instead, as that would be both misleading and potentially dangerous.
I literally couldn’t care less about how much magnesium is in Soylent. 99% of American consumers (and now Canadian, woop woop) just don’t care about this. That’s why the FDA doesn’t require a label. Also, [this] 1: “Overall, the risks of a typically healthy person ever suffering from a magnesium overdose are very, very low.”
Now, @nutrisludge, I’m sure we can all agree that your time is very important, which is why I’m baffled as to why you would waste so much of it on a topic of which… well…