1/24/19 • Food & NutritionNutrition Label

Corn Refiners Association Submits Letter to FDA Disclosing New Consumer Perception Survey Findings and Rulemaking Recommendations

WASHINGTON, DC – Today, the Corn Refiners Association (CRA) submitted a report to the US Food and Drug Administration’s (FDA) Center for Food Safety and Applied Nutrition (CFSAN), disclosing the findings of a recently conducted consumer perception survey and making recommendations for changing food label requirements for the claims “healthy” and “natural” to better reflect what consumers think the claims mean.

The nationwide online survey, conducted by Jayson Lusk, Ph.D., Head of the Department of Agriculture Economics at Purdue University, focused on respondent’s food values, including beliefs on “healthy” and “natural” product claims, willingness-to-pay, and beliefs about ingredient names.  The survey was commissioned by CRA, which had no editorial control over the report.

A sample of the study’s key findings include:

  • Regarding “healthy” —
    • About 40% of consumers thought that a “healthy” label claim implied that they should increase consumption of the food and 15% thought the label meant they could eat all that they wanted.
  • Regarding “natural” —
    • Apparent lack of knowledge regarding agricultural practices yielded inconsistent responses regarding products and the practices that produce them. The majority of survey respondents considered “organically grown crops” to be “natural,” but also considered pesticides used in organic production and the methods (i.e., mutagenesis) used to create organic seeds to be “not natural.”
  • Regarding ingredient names —
    • More than 85% of respondents preferred every-day, lay ingredient names to their scientific counterparts (e.g., corn starch vs. maltodextrin) insofar as the word being informative for consumer choice.

“The survey results provided to FDA today clearly indicate there is a major gap between the official meaning of ‘healthy,’ and ‘natural,’ and what consumers think those terms mean.” said John Bode, President and CEO of the Corn Refiners Association. “Based on this major survey, we recommend that FDA develop new regulations for ‘healthy’ and ‘natural,’ as well as switch to common food names, instead of scientific names in food ingredient declarations.  Consumer understanding should be the goal in setting food label terms.  That is why we are urging FDA to add high levels of sugar as a disqualifier for use of ‘healthy’ claims, even though our industry is a major producer of sugars,” said Bode.

In addition to disclosing survey results (which can be found in full here), CRA submitted the following rulemaking recommendations to FDA:

  • Undertake rulemaking to revise the requirements for “healthy” claims to include at least total sugars and require the claim be accompanied by a statement that indicates what the claim means.
  • Initiate rulemaking jointly with the USDA’s Food Safety Inspection Service (FSIS) to adopt a coordinated approach to regulation of “natural” claims. We recommend that the starting point in developing such a regulation should be a highly restrictive definition limited to “wash/clean/chop/grind/slice” of raw commodities. Further, to avoid likely consumer misunderstanding, the proposal should include a requirement for an accompanying statement that, “‘Natural’ does not indicate the food is healthier, safer or better for the environment, nor does it relate to agricultural production practices.”
  • Initiate rulemaking to permit use of consumer-understood common names of food ingredients in the ingredient declaration.

“CRA respectfully submits that since FDA’s statutory authority for regulation of food product labeling is the prohibition of false and misleading presentation of products, how terms are understood by consumers should guide agency rulemaking regarding such terms,” said Bode.


The Corn Refiners Association (CRA) is the national trade association representing the corn refining industry of the United States. CRA and its predecessors have served this important segment of American agribusiness since 1913. Corn refiners manufacture sweeteners, starch, advanced bioproducts, corn oil and feed products from corn components such as starch, oil, protein and fiber.