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: Labeling Requirements for Corn-Derived Syrups
Dear Dr. Califf:
As the FDA is aware, glucose (monosaccharide) is a natural saccharide (sugar) that is the life-sustaining blood sugar naturally present in all living organisms, molecular formula C6H12O6; i.e., it is not a man-made, laboratory-created saccharide. Therefore, corn-derived syrups (D-glucose) produced from allergenic cornstarch, molecular formula C6H14O7, cannot be classified as monosaccharides, since corn-derived syrups (D-glucose) are not naturally present in any living organism.
Labeling Requirements for Corn-Derived Syrups
What are the current labeling requirements for corn-derived syrups? If a product contains corn syrup (usual and customary name), is "corn syrup" required on the label? If a product contains HFCS (usual and customary name), is "high fructose corn syrup (HFCS)" required on the label?
In addition, corn syrup solids are the dry version of corn syrup (produced from allergenic cornstarch) which can prove fatal to anyone with an IgE-mediated allergy to corn. What are the current labeling requirements for identifying corn syrup solids in a consumable product?
If the “usual and customary names’ for corn-derived sweeteners/syrups (produced from cornstarch) are exempt from FDA labeling requirements, then they should be accurately identified as D-glucose (a polysaccharide) – NOT glucose (a monosaccharide).
Dr. Califf, for the protection of all consumers; particularly consumers with an IgE-mediated allergy to corn, we would appreciate your consideration of our inquiry.
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
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
