Comments on the Proposed Nutrition Label
Submitted by:
The Vegetarian Resource Group
PO Box 1463
Baltimore, MD 21203
July 29, 2014

Reed Mangels, PhD, RD, LDN, FADA
Nutrition Advisor, The Vegetarian Resource Group

Charles Stahler
Co-Director, The Vegetarian Resource Group

Debra Wasserman
Co-Director, The Vegetarian Resource Group

Thank you for the opportunity to submit comments on the Revision of the Nutrition and Supplement Facts Label.

The Vegetarian Resource Group (VRG) is an independent non-profit organization dedicated to educating the public on vegetarianism and the interrelated issues of health, nutrition, ecology, ethics, and world hunger. In addition to publishing the Vegetarian Journal, VRG produces books, pamphlets, and article reprints. Our health professionals, activists, and educators work with businesses and individuals to bring about healthy changes in schools, workplaces, and the community. Registered dietitians and physicians aid in the development of nutrition-related publications and answer questions about the vegetarian and vegan diet. Financial support comes primarily from memberships, contributions, and book sales. We support the proposed revisions to the Nutrition and Supplement Facts Label and offer additional
comments and suggestions.

Indicate the form of vitamin D which is being added to foods.
Vitamin D used in fortification and dietary supplements may be in the form of vitamin D2 (ergocalciferol)or vitamin D3 (cholecalciferol). The form of vitamin D which is added to foods is important to vegetarians. The vitamin D3 commonly used in supplements and fortified foods is derived from lanolin from sheep’s wool1 and is not considered to be vegan. Currently some foods and supplements simply list vitamin D without specifying the form. The addition of the requirement to specify the form of vitamin D would be helpful to vegans and to those who prefer to use a specific form of vitamin D.

Require that foods which are fortified with vitamin B12 indicate both the %DV and the absolute amount of vitamin B12 per serving.
Fortified foods and supplements are the only reliable way for individuals who avoid all animal products to obtain vitamin B12. Including the amount of vitamin B12 added to fortified foods and supplements would enable these individuals to monitor their intake of this essential vitamin. This labeling would also be helpful to those age 50 years and older who are advised to meet their RDA mainly by consuming foods fortified with crystalline vitamin B 12 or vitamin B 12-containing supplements.

Require that the source of ingredients that are often derived from animals be identified.
Vegetarians, those who keep kosher or Halal, and others who avoid animal products would benefit from ingredient lists that clearly indicate animal-derived ingredients. Some companies are already voluntarily identifying ingredients such as mono- and di-glycerides, L-Cysteine, and natural flavors as “vegetable” or “from non-meat sources” due to consumer demand. Requiring this type of labeling allows consumers to make informed choices. Our polls indicate that 47% of adults in the United States are eating one or more vegetarian meals each week.2

Consider overall nutrition value.
As advocates for health-promoting plant-based diets, we agree with former FDA head David Kessler, MD that “Whatever form those regulations ultimately take, their goal should be to encourage the sale and consumption of products full of fruits, vegetables, and whole grains, rather than those loaded with little more than fat, sugar, and salt.”3 This could be accomplished by the development of some sort of overall rating system for foods which would give highest ratings for foods based on fruits, vegetables, and whole grains and give markedly lower ratings for nutrient-poor foods which have been fortified with vitamins and minerals. Additionally, foods which are high in added sugars should not be able to make nutrition and health claims.

Keep the requirement that calcium and iron be included on the nutrition facts label.
Calcium and iron are essential nutrients which are of especial interest to vegans (vegetarians who do not use any animal products). The requirement to include both the %DV and the absolute amount of these nutrients in foods will help consumers (including vegans) to choose foods which are good sources of these nutrients.

Thank you for the opportunity to provide comments.

References
1. Yacoubou J. Vegetarian Journal’s Guide to Food Ingredients.
http://www.vrg.org/ingredients/index.php#vitamin_d. Partially updated 2010.
2. Stahler C. How often do Americans eat vegetarian meals? And how many adults in the U.S. are
vegetarian? The Vegetarian Resource Group blog. May 18, 2012;
http://www.vrg.org/blog/2012/05/18/how-often-do-americans-eat-vegetarian-meals-and-how-manyadults-in-the-u-s-are-vegetarian/
3. Kessler DA. Toward more comprehensive food labeling. N Engl J Med 2014; 371:193-195.