2 ms·

I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is

I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is probably not really problematic... straightforward concrete rules about the point you can no longer call the product "avocado oil" because it's so much something else are to me a perfectly reasonable exercise of the government's power. To some degree this kind of thing is at least theoretically covered by existing general provisions, but enforcement is likely to be laxer than necessary where the "line" is fuzzy and there's a likelihood of litigation over it. This is especially true for cooking oil, a major part of the differentiation between types and grades of oil is down to health benefits the consumer can't really detect on their own. Having solid rules that allow simple comparisons of the labeling that actually provide useful workable information is just providing the necessary framework for consumers to make informed choices. This is different from, say, being able to tell whether or not you like your frozen cherry pie in the absence of the puzzlingly unique and specific frozen cherry pie food standard. We definitely have a variety of legacy standards that aren't productive.

thaumasiotes 5y ago
> I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is probably not really problematic... straightforward concrete rules about the point you can no longer call the product "avocado oil" because it's so much something else are to me a perfectly reasonable exercise of the government's power So, the minor point is that this isn't a standard of identity. It'd be something different. The more important point is that what you're talking about doesn't make sense. There is no particular reason to think that "avocado oil" is a single-ingredient product any more than you would think the same of "pomegranate juice". By volume, most juices are apple juice or grape juice, for the excellent reason that, in order to even be palatable to most consumers, pomegranate juice (for example) requires heavy dilution. Apple and grape juice are used because their flavors are so weak. But you're not getting ripped off when you buy pomegranate juice; you're getting exactly what you want. The place to note that something is a single-ingredient product is in the ingredients list, like here: https://www.amazon.com/Kevala-Avocado-Oil-Fluid-Ounce/dp/B00ATAI4HC/ https://www.amazon.com/Kevala-Avocado-Oil-Fluid-Ounce/dp/B00... . And if the ingredients list is fraudulent, that isn't the same problem as the fact that some people are aesthetically opposed to the product's name.
- zerocrates 5y ago
  I agree that the basic "authenticity" part of this situation (where the product in fact claims to be entirely avocado oil and isn't) is already covered by existing authorities, and is basically a different problem. As for the rest of your post, well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place. My grocery store store brand will also sell you something like "No Sugar Added 100% Juice Cranberry Pomegranate" followed by very small letters reading "flavored blend of 5 fruit juices with added ingredients"... Welch's settled a lawsuit several years for doing this very thing with a product that at least was being even a little more up-front about being primarily white grape juice. As for there being no reason for people to think that something is what it claims to be, well I suppose that is a widely held belief that accounts for much of what we see in food labeling. I happen to think if you sell something that's 99% soybean oil and 1% avocado oil you shouldn't be able to call it "avocado oil" even if you are correctly listing the soybean oil first on the ingredients list. Or if it's 50/50 or 49/51 (and you can therefore list the avocado oil first) for that matter. Ultimately names do matter. There's a reason the manufacturers care at all about what they're able to call their products, because it does actually affect how consumers act. Feel free to sell an otherwise accurately labeled 50/50 blend, just actually call it a blend. I really don't think it's unreasonable that if you give something an unqualified name of something that is a single ingredient that consumers should expect it to in fact be that thing.
  - thaumasiotes 5y ago
    > well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place. You're saying it's widely available. I'm saying it's not widely consumed. And I stand by my opinion that naming a blended product after its most prominent flavor is both normal and desirable. But I see no issue with requiring blends to be labeled as blends. The regulation described sidethread here ( https://news.ycombinator.com/item?id=30106290 https://news.ycombinator.com/item?id=30106290 ) seems pretty reasonable to me. > 1. The indication of the quantity of an ingredient or category of ingredients used in the manufacture or preparation of a food shall be required where the ingredient or category of ingredients concerned: > (a) appears in the name of the food or is usually associated with that name by the consumer; > (b) is emphasised on the labelling in words, pictures or graphics; or [another clause] But even in that case, you're free to sell something as "avocado oil" when it's 50% avocado-derived or even 20% avocado-derived [consider something like "garlic olive oil"]; you just need to disclose the amount.

thaumasiotes 5y ago

> I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is probably not really problematic... straightforward concrete rules about the point you can no longer call the product "avocado oil" because it's so much something else are to me a perfectly reasonable exercise of the government's power So, the minor point is that this isn't a standard of identity. It'd be something different. The more important point is that what you're talking about doesn't make sense. There is no particular reason to think that "avocado oil" is a single-ingredient product any more than you would think the same of "pomegranate juice". By volume, most juices are apple juice or grape juice, for the excellent reason that, in order to even be palatable to most consumers, pomegranate juice (for example) requires heavy dilution. Apple and grape juice are used because their flavors are so weak. But you're not getting ripped off when you buy pomegranate juice; you're getting exactly what you want. The place to note that something is a single-ingredient product is in the ingredients list, like here: https://www.amazon.com/Kevala-Avocado-Oil-Fluid-Ounce/dp/B00ATAI4HC/ https://www.amazon.com/Kevala-Avocado-Oil-Fluid-Ounce/dp/B00... . And if the ingredients list is fraudulent, that isn't the same problem as the fact that some people are aesthetically opposed to the product's name.

zerocrates 5y ago
I agree that the basic "authenticity" part of this situation (where the product in fact claims to be entirely avocado oil and isn't) is already covered by existing authorities, and is basically a different problem. As for the rest of your post, well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place. My grocery store store brand will also sell you something like "No Sugar Added 100% Juice Cranberry Pomegranate" followed by very small letters reading "flavored blend of 5 fruit juices with added ingredients"... Welch's settled a lawsuit several years for doing this very thing with a product that at least was being even a little more up-front about being primarily white grape juice. As for there being no reason for people to think that something is what it claims to be, well I suppose that is a widely held belief that accounts for much of what we see in food labeling. I happen to think if you sell something that's 99% soybean oil and 1% avocado oil you shouldn't be able to call it "avocado oil" even if you are correctly listing the soybean oil first on the ingredients list. Or if it's 50/50 or 49/51 (and you can therefore list the avocado oil first) for that matter. Ultimately names do matter. There's a reason the manufacturers care at all about what they're able to call their products, because it does actually affect how consumers act. Feel free to sell an otherwise accurately labeled 50/50 blend, just actually call it a blend. I really don't think it's unreasonable that if you give something an unqualified name of something that is a single ingredient that consumers should expect it to in fact be that thing.
- thaumasiotes 5y ago
  > well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place. You're saying it's widely available. I'm saying it's not widely consumed. And I stand by my opinion that naming a blended product after its most prominent flavor is both normal and desirable. But I see no issue with requiring blends to be labeled as blends. The regulation described sidethread here ( https://news.ycombinator.com/item?id=30106290 https://news.ycombinator.com/item?id=30106290 ) seems pretty reasonable to me. > 1. The indication of the quantity of an ingredient or category of ingredients used in the manufacture or preparation of a food shall be required where the ingredient or category of ingredients concerned: > (a) appears in the name of the food or is usually associated with that name by the consumer; > (b) is emphasised on the labelling in words, pictures or graphics; or [another clause] But even in that case, you're free to sell something as "avocado oil" when it's 50% avocado-derived or even 20% avocado-derived [consider something like "garlic olive oil"]; you just need to disclose the amount.