The Honorable Thomas 1. Vilsack
Secretary of Agriculture
United States Department ofAgriculture
1400 Independence Avenue, SW
Whitten BufldlDs. Room 200A
Washington. DC 20250
The Honorable Jon Leibowitz
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20S80
July 15,2011
The Honorable Margaret A. Hamburg
Food Bft4 Drua Admiuistratie>n
10903 New Hampshire Avenue
Building ), R.i3om 2217
SllvCf Spring, MD 20993
The Honorable Thomas R. MD, MPH
e.rsfor Disease Control and Pre:vcmtion
1600 Clifton R.oad
Atlanta, OA 30329-4018
Dear Secretaty Vilsack, Chabman Leibowitz,. Commissioner HambufS
and Director Frieden:
We understand that an Interagenc1 Worldng Group (lWG) compriseQ ofth. U.S. Department of
Agriculture, Federal Trade Conunission. U.S. Food and Drug AdmiDistration
and the Centers for
Disease Control md Prevention recently relessed proposed gIlideHnes for food and beverage marketing
to childrrm IUld teens. Tho guideliaos. ''Preliminary Proposed Nutrition Principles to Guide Industly
SelfwR.egulatoXy Efforts,II would requJ:e all food marketed to children and toens meet two nutrition
principles: one. that foods contribute 8l1isnincIDt amount of certain foods StOUps (e.g. hits, vegetable&,
whole grains, em); and two, that foods have very low amounts of eatunl1ed fat, trans fat. added sugaI'II,
and sodium.
We certainly agree that childhoDd obesity is a challenge deserling our attention. However. after
reviewing the proposed prinoiples, wo have a few questiona regerdlna the impacts that these
gwdeImes-iffullyadopted-will have on the U.S. economy and the U.S. food 8Jld agricultural
industries. Please provide for us the data to answer the questions below.
Oiven that the 2005 Institute ofMedicine report. "Food Markeringto Children and Youth! Threat
or Opportunity?", found there was not sufficient evidence to find a causal relationship between
advertising and obesity, what data did the IWG use to demonstrate alinlc between advertising
ad obesity?
What data was used to SUP,POl't recommendations that are different than the science-based
nutritional :ecommendations utilized. in the Fcdcral acho.o! Meals Programs and other nutrition
assistance,Ptoarams for children? Further. what data was used to support recommendations that
are different than the requirements estabU,hed by USDA and FDA to designate products as
"Low Pat" or "Healthy?"
What impact will these guideHnes have on the consumptiOJ1 ofvarious foods end food smuJ'S
(e.g- cereal, wheat bread, oatmeal, rice, beef: poultry. pork products. fluid milk
yogurt. cheese
nuts, legumes. fruits. and vegetables)? \Vbat economic impact win these principles have on U.S.
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I-'M Ottlce ot 5el'lator Joh;;r.r.s 202-228-0436
Lettcrto Secretaty Vilsack. Chairman Leibowitz. Cormnissioner Hamburg, and Director Frieden
July IS, 2011
Page 2
producers and ofthese products? What implications did the agencies determine with
.regard to jobs 1n these impacted areas?
Given the broad definition of'lnarketint
in the proposal, W8 understand that businesses may be
limited from providing support 10 school aod communitr philantbropio activities; including
sports teams. literaoy progmms, and other hea.lthhptomotinl youth activities. What analysis was
done regarding the eoonomic impaotto schools and oommunitie8?
It is important lbat we consider and understand the Impact that tbia proposal win have on the
various sectors ofthe U.S. economy as well as COZWlmers and young people. Thus. we look forward to
receiving the IWO's ;respOnse to these imporhlnt questions. In the interim, we uk"that you withhold any
1Urther action, except for the process ofanalyzing comments to the proposal.



cc: norable Kathleen Sebelius,
of1he Department ofHealth and Human Services

JUL-1S-2011 06:03 202 228 0436 95% P.003

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