The evaluation from CRN on the proposed labeling changes commended FDA for proposing to continue using the Recommended Dietary Allowance (RDA), when available, as the basis for determining the Reference Daily Intakes (RDIs) for nutrients. According to CRNs review, “Basing the RDI on the Estimated Average Requirement (EAR), which was considered by FDA in developing the proposed rule, would effectively dilute the nutrient requirements for Americans since the EAR represents the daily intake level estimated to satisfy the needs of only half of the people in each life-stage and sex group. In contrast, an RDI based on an RDA would meet the daily requirements of nearly all (97.5%) healthy individuals in a given group.”
CRN expressed that maintaining an RDA-based RDI is critical given the significant nutrient shortfalls among U.S. citizens. The report cited a recent analysis which found that “54.5% of Americans fall short of the average requirement for magnesium when considering intake from food alone,” as a prime example for the extent to which Americans fail to meet nutritional benchmarks.
CRN concurred with FDA’s current conclusion that RDIs for vitamins and minerals should continue to be based on a population-coverage approach, which use the highest age/gender group RDA value (or highest AI, where an RDA has not been established). The report also expressed support of FDA’s assertion that the population-coverage approach would cover vulnerable or at-risk groups sufficiently. “Using the population-weighted approach instead would result in a higher risk of nutrient inadequacy for some population groups because the RDIs would be derived by averaging the nutrient requirements for groups with lesser needs and those with greater needs,” explained CRN.
FDA addressed concerns over the risk of excessive intakes of nutrients through the use of the current and proposed population-coverage and RDA-based approach for determining RDIs, which CRN applauded. Based on a thorough analysis of NHANES (2003-2006) data, FDA concluded that “total nutrient intakes (from both conventional foods and dietary supplements)...do not exceed the [Tolerable Upper Levels] for most vitamins and minerals.” CRN agreed with FDA’s evaluation.
CRN’s comments also offered specific guidance on proposed labeling for Vitamin B12, Choline, Vitamin D and Potassium, Vitamins A and C, Folate and Folic Acid, Dietary Fiber, Protein, in addition to other key nutritional components.
For CRN’s full commentary on the proposed label changes, visit crnusa.org.