September 27, 2022
Robert M. Califf, M.D. (CERTIFIED)
Commissioner of Food and Drugs
U.S. Food and Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
Re: “Glucose Syrup“ Ingredient
Dear Dr. Califf:
As the FDA is aware, glucose is a simple sugar (a monosaccharide) that is naturally present in all living organisms which is essential for their survival, molecular formula C6H12O6. Therefore, glucose is NOT a man-made, laboratory-manufactured saccharide (sugar).
Some food manufacturers are listing ”glucose syrup” as an ingredient on food labels; e.g., KIND Food Company. Since glucose is essential for the survival of all living organisms, the labeling of “glucose syrup“ as an ingredient may lead consumers to believe this product is essential for their survival.
Caramel Nut Protein Bar
Ingredients: Peanuts, almonds, glucose syrup, [emphasis added] soy protein isolate, honey, chicory root fiber, palm kernel oil, sugar, milk powder, soy lecithin, carob powder, sea salt, natural flavor, annatto.
https://www.kindsnacks.com/protein-bars/caramel-nut-M20803.html
I could not locate any reference for ”glucose syrup“ [https://www.fda.gov/food/food-additives-petitions/food-additive-status-list#ftnG] or “syrup, glucose“ [https://www.fda.gov/food/food-additives-petitions/food-additive-status-list#ftnS] on the FDA’s Food Additive Status List.
If “dextrose“ is referenced on the FDA’s Food Additive Status List, it refers the reader to 184.1857 [https://www.fda.gov/food/food-additives-petitions/food-additive-status-list#ftnD], and 184.1857 defines dextrose as “Corn sugar“ [https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=184.1857].
It is apparent that “glucose syrup“ is not referring to corn syrup, since the molecular formula for corn syrup (produced from cornstarch, a polysaccharide) is C6H14O7, and the molecular formula for glucose (life-sustaining blood sugar naturally present in all living organisms, a monosaccharide) is C6H12O6. Therefore, glucose and corn syrup cannot be one and the same; since corn syrup can prove FATAL to anyone with an IgE-mediated allergy to corn.
Corn Syrup, PubChem CID 5282499, Molecular Formula C6H14O7
https://pubchem.ncbi.nlm.nih.gov/compound/Corn-syrup#:~:text=Corn%20syrup%20%7C%20C6H14O7%20%2D%20PubChem
Please confirm, in writing, the complete description and labeling requirements of this undefined food ingredient. In addition, please confirm, in writing, if this ingredient is classified as a monosaccharide, disaccharide, or polysaccharide with the corresponding molecular formula.
Since this undefined food ingredient is appearing more frequently on food labels, I recommend that the FDA include the applicable reference for this ingredient on the FDA’s Food Additive Status List as soon as possible for the safety of all consumers.
Dr. Califf, thank you very much for your attention to this critical concern.
Sincerely,
Diane H., Corn Allergy Advocate
Corn Allergy Advocacy/Resources
https://cornallergyadvocacyresources.blogspot.com/
Email: cornallergyinitiative@gmail.com
Twitter: @CornAllergy911
References:
What are the four kinds of saccharides?
"Monosaccharides are the simplest carbohydrates in that they cannot be hydrolyzed to smaller carbohydrates."
https://byjus.com/question-answer/what-are-the-four-kinds-of-saccharides/
"Difference between monosaccharide, disaccharide and polysaccharide,” A-Level Biology
https://alevelbiology.co.uk/notes/monosaccharide-disaccharide-polysaccharide/
"Determining the General Molecular Formula of a Monosaccharide and Working Out the Molecular Formula of a Disaccharide Composed of Two Molecules of a Given Monosaccharide"
https://www.nagwa.com/en/videos/743137295710/#%3A~%3Atext%3Dusing%20general%20formulas.-%2CWhat%20is%20the%20general%20molecular%20formula%20of%20a%20monosaccharide%3F%2Cjoin%20by%20a%20condensation%20reaction
Nutritive Sweeteners from Corn [D-glucose], Corn Refiners Association
[Over a period of many decades, the "D-" modifier has been shortened to "glucose" for convenience purposes. Dextrose (D-glucose/corn sugar produced from allergenic cornstarch) is NOT naturally present in humans, and can KILL anyone with an IgE-mediated allergy to corn.]
https://corn.org/wp-content/uploads/2018/10/NSFC2006.pdf
My August 5, 2022, Certified Letter to the FDA Commissioner Re: Dextrose (Corn Sugar/D-Glucose) is Not Naturally Present in Any Living Organism
https://cornallergyadvocacyresources.blogspot.com/2022/08/my-august-5-2022-certified-letter-to_47.html
My August 5, 2022, Certified Letter to the FDA Commissioner Re: Conflicting Molecular Formulas
https://cornallergyadvocacyresources.blogspot.com/2022/08/my-august-5-2022-certified-letter-to_74.html
My December 14, 2021, Email to the Board of Trustees, American Medical Association (AMA) Re: Dextrose (Corn Sugar) / Conflicting Molecular Formulas
https://cornallergyadvocacyresources.blogspot.com/2021/12/my-december-14-2021-email-to-board-of.html
My August 5, 2022, Certified Letter to the FDA Commissioner Re: HFCS (Essential for Human Survival?)
https://cornallergyadvocacyresources.blogspot.com/2022/08/my-august-5-2022-certified-letter-to_31.html
Dextrose Equivalent (DE) from corn syrup solids which can prove FATAL to anyone with an IgE-mediated allergy to corn.
https://digitalcommons.usu.edu/etd/4804/
Read more: Difference Between Sugar and Corn Syrup | Difference Between
"Sugar is classified as a disaccharide (two molecules) while corn syrup (as it is made from starch) is a polysaccharide (many molecules)." [emphasis added]
http://www.differencebetween.net/object/comparisons-of-food-items/processed-foods/difference-between-sugar-and-corn-syrup/#ixzz7ccCjcyov
DISTRIBUTORS OF "GLUCOSE SYRUP" [Mislabeled Consumer Products.]
Glucose Standard Solution, Laboratory Grade, 500 mL
Synonym: Dextrose [emphasis added]
[Dextrose is corn sugar produced from allergenic cornstarch, D-glucose; NOT glucose (life-sustaining blood sugar naturally present in all living organisms), 21CFR184.1857.]
https://www.carolina.com/catalog/detail.jsp?prodId=865393&gclid=Cj0KCQjwsrWZBhC4ARIsAGGUJurYmthCJjpJWuRRbMbQre4EPLZumEuQQp-4qxyPhPPgUhmUDkVaNeUaAuBvEALw_wcB
Gold Medal 4160 60 lb Can Glucose for Caramel Corn, Candy Apples
"Glucose, 42/43 Degrees Baume corn syrup, [emphasis added] 60 lb. Can"
[Corn syrup manufactured from allergenic cornstarch is D-glucose; NOT glucose.]
https://www.katom.com/231-4160.html?gclid=Cj0KCQjwsrWZBhC4ARIsAGGUJuqNtQmT3neXsJS3ZfzP4ONmwmoCPd4W6ExD2Q5Zy2uClpW80JQGl4IaAlWOEALw_wcB
D-Glucose-1-d (CAS 106032-61-5)
"D-Glucose-1-d is a labeled D-Glucose which is a simple sugar that is present in plants." [emphasis added]
[D-Glucose is corn sugar produced from allergenic cornstarch (dextrose), 21CFR184.1857, and is NOT a “simple sugar that is present in plants.”]
https://www.scbt.com/p/d-glucose-1-d-106032-61-5?lang=en&cur=usd&gclid=Cj0KCQjwsrWZBhC4ARIsAGGUJurZhf20H-d9pqy3xNW8q0qOtoAkokVIOrY8Hy-cO9TaM1kZOIbH6yUaAvZSEALw_wcB
Batory Foods, Glucose Syrup Solids [This product should be labeled as “Corn Syrup Solids.”]
Glucose solids are comprised of dried glucose syrup obtained by acid conversion of common corn starch. [emphasis added]
https://www.batoryfoods.com/food_product/glucose-syrup/
Wilton Glucose Syrup
The only ingredient listed is “Corn Syrup.” Corn syrup manufactured from allergenic cornstarch is D-glucose, molecular formula C6H14O7 – NOT glucose, molecular formula C6H12O6.
https://www.instacart.com/landing?product_id=19641322&retailer_id=1379®ion_id=17851473879&utm_medium=sem_shopping&utm_source=instacart_google&utm_campaign=ad_demand_shopping_rp_food-pantry&utm_content=accountid-8145171519_campaignid-16074540121_adgroupid-129731642810_device-c&gclid=Cj0KCQjwuuKXBhCRARIsAC-gM0gFeuAyENvi3KIF8n77wVCT2xVJs7zwJqE9loZ8pbc-R5EWSJRln58aAuivEALw_wcB
Welleus Global Solutions LLC
This medical supply company is selling "Glucose Drink;" therefore, they are insinuating that this product is essential for human survival.
https://medicalproductssupply.com/glucose-drink-orange-100-g.html?gclid=Cj0KCQjwuuKXBhCRARIsAC-gM0itSRAAiPT6Jf9sg76DxnfjO8iA9p0iWrDMgs34K21bWYn-BdHeuxEaAkZQEALw_wcB
Tate & Lyle
"Glucose Syrups are a range of nutritive sweeteners produced from corn."
[This should state: "D-Glucose Syrups are a range of nutritive sweeteners produced from corn."]
https://www.tateandlyle.com/ingredient/glucamyl-glucose-syrups
Pike Global Foods
This company is selling “Glucose Syrup,” and identifies the only ingredient as “Glucose.” Therefore, since glucose is essential for the survival of all living organisms, this manufacturer is leading consumers to believe this product is essential for their survival.
https://www.pikeglobalfoods.com/glucose-syrup-11-lbs/?gclid=Cj0KCQjwuuKXBhCRARIsAC-gM0hOCogYPpORgnIqpORAB_6t55f8YuYxtTDxeGzGZwLNioUOn56b-tMaAnD_EALw_wcB#description
