New Foods with New Names. Robert M. Reeves Public Affairs Director, QUALISOY
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1 New Foods with New Names Robert M. Reeves Public Affairs Director, QUALISOY GMA Science Forum May 19, 2011
2 Food Names Statement of Identity featured on principal display panel of label (21CFR101.3) Shall be in terms of: The name specified by law or regulation or, The common or usual name or, in the absence of, An appropriately descriptive term, or a fanciful name commonly used by the public when the nature of the food is obvious
3 Key Reasons for Developing Common or Usual or Fanciful Names Avoids consumer confusion associated with complex, chemical-sounding names Examples: low erucic acid rapeseed oil (canola) or Rebaudioside A (Rebiana or TruviaTM), a non-caloric natural sweetener Facilitates consumer understanding Enhances ability to market new products/ingredients
4 Examples of Fanciful Names for Food Ingredients Aspartame Artificial sweetener, 21CFR % L-aspartic acid, 50% L-phenylalanine, 10% methanol Canola Cultivar of rapeseed, 21CFR Name derived from geographic source (Canada) and the connotation of ola with low erucic acid Tangelo Hybrid citrus fruit Name derived from mixture of source fruits: tangerine + pomelo or grapefruit
5 Common or Usual Name: Basic Requirements Mandatory in ingredients statements Must be truthful and non-misleading Must be understandable by consumers
6 Common or Usual Name: General Principles (21CFR102.5) for Non-Standardized Foods May be a coined term, shall accurately describe the basic nature of the food or its characterizing properties Shall be common among all identical or similar products May not be confusingly similar to the name of any other food
7 Basic Methods to Gain Approval of a New Common or Usual Name Petition (21CFR Part 10) Action requested Statement of grounds or justification Environmental impact Economic impact Informal request Approach FDA with justification for a new common or usual name Provide research supporting consumer understanding of the name Supply additional information as required
8 Industry Considerations Industry considerations in developing brand names may apply to common or usual names: Unity in value chain for new name Avoid duplicating existing trademarked names Fit of common name with current product brands Easy pronunciation of name Reflection of positive attributes (e.g. natural, healthy) Indicative of good taste or flavor
9 New Common or Usual Name for Higholeic Soybean Oil Objective: Increase consumer understanding by avoiding technical terms [e.g. high oleic acid soybean oil (HOSBO)] Method: Informal request with FDA Provide consumer understanding research (online surveys, focus groups) Explain safety benefits (avoids trans fats due to high oxidative stability, thus no hydrogenation) Consider evolution of use and phase-in common or usual name over 2-3 years
10 Benefits of a Common or Usual Name for the Value Chain of an Agricultural Commodity Provides unification for industry sector Seed Developers Farmers Increases awareness around product and enhances promotional activity Improves effectiveness of marketing Oilseed Processors/Oil Refiners Food Manufacturers Simplifies labeling of products Easy identification of product that communicates product benefits Health Community Influencers Consumers Easy recognition of product Simplifies educational/ marketing efforts
11 Potential Regulatory Considerations May be interpreted as being a nutrient content claim or health claim Implied references to increased unsaturated fatty acids or decreased saturated fatty acids Precedent-setting nature of common names for fatty-acid modified vegetable oils Understanding by consumers? Descriptive enough? Consumer research protocols should be similar to those of statistical studies meeting OMB guidelines
12 Criteria for HOSBO Common Name Oleic acid content level or range Accommodates variations in climate, soil, cultivars, etc. Other compositional factors Lowered saturated fat content Functional characteristics Example of potential common name for HOSBO: Soyola
13 Summary Common or usual names must be carefully planned to meet regulatory requirements and industry objectives Consumer understanding a major factor (truthful and non-misleading) Must describe basic nature of food
14 Thank you! Questions?
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