Wednesday, December 20, 2006

Guacamole dip with no avocado -- a food policy lesson in "standards of identity"

It has been fun to follow recent coverage of Kraft's guacamole dip, whose label the company changed a few months ago when people complained that the product has little avocado in it. "A thunderous 'No!' to faux guacamole," says Tom Philpott. "Yum," says Chowhound, although one suspects sarcasm after following the link to Jerry Hirsch of the Los Angeles Times (via Seattle Times):
The guacamole sold by Kraft Foods Inc. ... calls for modified food starch, hefty amounts of coconut and soybean oils and a dose of food coloring [Note 12/21: slight correction, see comments].
A column by Fortune's Marc Gunther today picks up the story of the faux guacamole as one example of "misleading labels [that] raise a bigger issue, and it's called trust." The column links to U.S. Food Policy. Gunther, who keeps a weblog and is author of Faith and Fortune, continues in today's column:
At a time when trust in big business is low - and when the food industry, fairly or not, faces escalating concern over the epidemic of obesity in the United States - you would hope, and think, that the industry would go out of its way to avoid marketing practices that are even potentially misleading.
Are there no rules about this sort of thing?

You may be surprised that it is legal to call a paste "guacamole dip" if it has minimal amounts of avocado. In fact, the federal government does have such rules, called "standards of identity," for hundreds of food products. Here is a Food and Drug Administration (FDA) announcement last year about possible changes to these standards.

Looking deep within the Code of Federal Regulations on this topic (see sections 130 to 169), I could find many related products, but no guacamole. I know you will be pleased to find that products that do have a standard of identity are required to have the nice simple ingredients you would expect.

For example, here is a brief excerpt of the long standard for "catsup":
... Such liquid is strained so as to exclude skins, seeds, and other coarse or hard substances in accordance with current good manufacturing practice. Prior to straining, food-grade hydrochloric acid may be added to the tomato material in an amount to obtain a pH no lower than 2.0. Such acid is then neutralized with food-grade sodium hydroxide so that the treated tomato material is restored to a pH of 4.20.2. The final composition of the food may be adjusted by concentration and/or by the addition of water. The food may contain salt (sodium chloride formed during acid neutralization shall be considered added salt) and is seasoned with ingredients as specified in paragraph (a)(2) of this section. The food is preserved by heat sterilization (canning), refrigeration, or freezing. When sealed in a container to be held at ambient temperatures, it is so processed by heat, before or after sealing, as to prevent spoilage....
Just like grandma used to make.


Anonymous said...

Well, I dunno, I think this is a little bit of a cheap shot. The identity standards in general prevent manufacturers from passing off fake foods on consumers. You can always find something to criticize, but in general, they've worked well.

Whenever an identity standard is up for a change, the entire process is out in the open. Take "barbecued meat": the standards are pretty strict there. Your mom's homemade "barbecue" wouldn't pass muster. The meat has to be slow cooked for long periods in certain ways at low temperature. This is really not practical outside of 'cue joints with special equipment, so you don't see a lot of mass marketed barbecue in the stores. Food scientists have come up with ways to duplicate the process, and they have petitioned to have the standard of identity changed. The documentation at the USDA on this is pretty extensive. Anyone is welcome to contribute to the public comments, w hich can be done over the internet.

The standards can be too strict. Wolfgang Puck tried to bring out pizza without tomato sauce. This was blocked until his distributor could petition for a change in identity standards, which was readily granted.

Sometimes changes just represent changing public policy. "Ice milk" became "low-fat ice cream." "Ice milk" had a stigma. But overall it was considered to be healthier: just ice cream with less cream. Why hobble the marketing efforts of companies trying to sell it?

Unknown said...

These standards of identity are fascinating. Must be a strange job to write them. I see the govt has one for pineapple juice, but not for "peach-papaya drink" which, as my column noted, is made by Tropicana and includes neither.

One small correction to your post and to the LA Times story that broke the news of the guacamole lawsuit--the Kraft guacamole dip is not a best seller, it has less than 3% of the market.

And thanks for the link, Parke!

usfoodpolicy said...

I agree with both mark and marcgunther's comments, which seem to reflect admiration for the "strange job" of trying to compile these standards and -- in mark's case -- a sense that it would be impossible for the standards to satisfy everybody. I found the catsup example amusing and informative, not necessarily to be criticized. The catsup example makes me truly unsure whether ever more and more detailed requirements for products as obscure as guacamole dip are the best road to better consumer information about the products.