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Article: Wine industry petitions FDA to allow wine to use a different methodology to count carbohydrates
17 June 2020
In a new petition to FDA, the US wine industry has asked the
agency to switch to a different method for calculating
carbohydrates in wine, a move that wine makers say would give
consumers a more accurate representation of wines' carbohydrate
content.
Filed June 8 by the Wine Institute, which represents California
wineries, and WineAmerica, the National Association of American
Wineries, the petition states the method FDA currently uses
"significantly" overstates the level of carbohydrates in wine.
"This overstatement disproportionately harms wine in the
marketplace," the wine groups said in the petition.
To avoid that, and to prevent unfair comparisons of the
carbohydrate content in wine versus that in other alcoholic
beverages, the groups are asking FDA to amend its regulations,
permitting use of an accurate "quantitation and summation of
sugars" approach as an approved method for calculating total
carbohydrate content in wine and wine-based beverages.
"Carbohydrate declarations need to be accurately expressed, both
to be in accordance with regulations and so as not to misrepresent
or mislead consumers," the two wine industry groups wrote in the
petition.
This is an important issue for the wine industry, even though
FDA currently does not require all wines to provide nutrition
information on all wine labels, stressed Robert Koch, the Wine
Institute's president and CEO, and James Trezise, president of
WineAmerica, who signed the petition.
In some cases, winemakers offer nutrition label information
voluntarily and for the benefit of consumers. Additionally, wine
producers must include nutrition labeling, including carbohydrate
content, on all wines that contain less than 7% alcohol by volume,
Koch and Trezise noted.
And under the new menu labeling requirements that went into
effect in May 2018, chain restaurants and other similar food
establishments are required to provide written information for
standard menu items specifying the amounts of several nutrients,
including total carbohydrates, if consumers request the
information, the petition said.
Specifically, the two wine groups take issue with the FDA
regulation governing nutrition labeling of food outlined in 21 CFR
§101.9, which requires that total carbohydrate content of wine be
calculated using a specific "by difference" method described by
Merrill and Watt in Energy Value of Foods: Basis and Derivation
found in USDA's Agriculture Handbook No. 74.
Current methods inaccurately represent carbs in wine,
petition says
But the use of that method has limitations and it becomes
problematic when applied to wine, the wine groups told FDA.
"Notably, the carbohydrate by difference method was designed to
determine the energy content of foods and not to measure
carbohydrates. The calculation was designed for its robustness in
the energy calculations, as any errors in protein determination are
offset by a higher or lower carbohydrate energy value," Koch and
Trezise explained.
And when applied to wine, the "by difference" method renders
inaccurate results, as the method estimates carbohydrate content by
including non-carbohydrate compounds, such as organic acids and
glycerol. As a result carbohydrate levels in wine become
significantly overestimated, which provides consumers with
inaccurate information and may lead them to make "ill-informed"
choices in relation to wine, the wine groups said.
"Wine contains a high relative concentration of organic acids
and glycerol, resulting in an inaccurate and significant
over-estimation of total carbohydrate when estimated using the
carbohydrate by difference method," Koch and Trezise said in the
petition. "Wine Institute and WineAmerica believe that the organic
acids and glycerol in wine are not carbohydrates and thus should
not be included as carbohydrates in nutrition information for
consumers."
Glycerol, organic acids should not count as carbs for
wine
Among the minor components of wine, glycerol and fixed acids
together represent nearly two-thirds of wine's composition, the
petition noted.
And even the authors of Handbook No.74 acknowledged that
"addition to the true carbohydrates, this 'difference' fraction may
include such compounds as organic acids," the wine groups said.
"In other words, the authors acknowledged that organic acids are
not true carbohydrates," Koch and Trezise wrote. "On page 6, the
authors confirm this, and point out that, in those foods containing
abundant organic acids, a separate estimation of those acids should
be made when determining energy values, because they are chemically
distinct from carbohydrates and have different heats of
combustion."
Also, the Handbook lists grapes as one of the foods for which
the carbohydrate by difference method "will not give accurate
results, in view of the abundant content of organic acids in
grapes," the wine groups said.
"The authors of Handbook 74 recognized that organic acids should
not be counted as carbohydrates and that the carbohydrate by
difference method is not accurate for foods with a high organic
acid content."
The petition applies similar arguments for glycerol (glycerin)
with the wine groups arguing that it should not be classified as a
sugar alcohol and, therefore, not as a carbohydrate.
"Generally speaking, sugar alcohols are composed of 5- or
6-carbon chains, since they are derived from 5-carbon or 6-carbon
sugars (pentoses and hexoses, respectively). Glycerol, however, is
only a 3-carbon polyol," the groups said.
FDA appears to have recognized that glycerol is not a sugar
alcohol because the Federal Register notice of FDA's final
nutritional labeling rule "specifies the calories per gram that are
to be used for each of the 'sugar alcohols.' However, that list
does not include glycerol," the petition said.
Glycerol metabolizes differently than sugars, and while glucose
"travels through the bloodstream and is generally metabolized
intracellularly in every cell in the body for energy, glycerol
kinase, the predominant enzyme responsible for glycerol metabolism
is primarily present in the liver, indicating that most of the
glycerol would be metabolized there," the petition noted.
"While a portion of ingested glycerol, whether consumed as
glycerol per se, or as a triglyceride, may be converted to glucose
via gluconeogenic pathways, such is also the case for many other
food components such as organic carboxylates (i.e., lactate), and
amino acids (e.g., alanine, and glutamine), which are not
classified as carbohydrates," the wine groups stated.
Summation of sugars - a more accurate way to estimate
wine's carb content
Based on these arguments, the wine groups' petition argues that
an approach based on the summation of sugars would be a more
appropriate method for calculating the level of carbohydrates in
wine. Analytical technology has advanced significantly since
Handbook No.74 was written in 1973, and a new method for the
analytical determination of glucose and fructose in wine has been
developed that allows for more exact calculation of the level of
carbohydrates.
"This new method has been accepted by the AOAC as Official
Method 985.09," the petition said. The method is based on an
enzymatic reaction, utilizing the enzyme hexokinase to catalyze a
reaction with glucose and fructose.
"This creates compounds that undergo further reactions to form a
very specific chemical that can then be selectively analyzed using
a simple spectrophotometer, common in most laboratories. This
highly selective method provides a much more accurate quantitation
of glucose and fructose than earlier analytical approaches."
Additionally, the analysis of sugars using High Performance
Liquid Chromatography (HPLC) is another method that was developed
after the publication of Handbook 74, the petition noted.
"In an effort to address the inaccuracy inherent in the
carbohydrate by difference method, the Wine Institute commissioned
the development of an HPLC method for the measurement of sugars,
which was accepted by the AOAC as First Action 2013.12 and
published in the Journal of the AOAC International in
2014," the petition said.
Considering that such methods are available and fix inaccuracies
in the current methodology for calculating carbohydrate content,
the Wine Institute and WineAmerica have requested that FDA amend
subparagraph (c)(6) in 21 CFR §101.9, Nutrition Labeling of Food,
and allow the summation of sugars to be used for calculating
carbohydrate content in the case of wine and wine-based beverage
products.
"As we have shown, the inaccurate method as currently prescribed
disproportionately harms wine in the marketplace and is misleading
to consumers," Koch and Trezise told FDA.
"The Wine Institute and WineAmerica respectfully ask the
Commissioner to review this Citizen Petition and move to implement
the requested amendment to 21 CFR §101.9(c)(6) expeditiously so
that wineries may provide consistent, accurate, and fair
declarations of carbohydrate content in wine to consumers, while
meeting the requirements of 27 CFR §4.39 (a)(1)."
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