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Glycemic Research Institute® 
Publication at USDA Website


Nutrition and Your Health:
Dietary Guidelines for Americans


Utilizing the clinically proven glycemic index of a food and/or raw material is mandatory in identifying "Net Carb" and "Low Carb" foods, as well as any claims for Diabetic-Friendly foods.

COMMENTS: The Glycemic Research Institute 

RE: Food Labeling and the Glycemic Index. Low Carb labeling and Sugar Alcohols. 


Dear Sirs; Our research organization has been conducting clinical studies of the Glycemic Index and human biochemistry for over 20 years. We possess the largest database of glycemic research of any organization in the world. We recently completed clinical for Hershey Foods to identify the biochemical pathway utilized by chocolate in the body. 


Our clinical studies are conducted in our laboratory, and include glycemic index, glycemic load, and fat-storing mechanisms in humans, such as Leptin, Lipoprotein Lipase, and Neuropeptide Y. 


We are submitting our comments to provide scientific evidence that: 

• Sugar alcohols can elevate blood glucose and insulin levels, and and stimulate fat-storage in humans, and this needs to be reflected in FDA labeling guidelines. 

Determination of the glycemic response of foods, Nutraceuticals, and all consumables, is mandatory in the determination of labeling information. 

Identifying "Low Carb" foods and "Net Carb" foods requires knowledge of the biochemical properties of the food. 


We concur with the FDA position that the term "Low Carb" should not be allowed until a competent definition on "Low Carb" is established. If the glycemic index of a low carb product is not known, how can that product claim not to elevate blood glucose, insulin levels, and stimulate fat-storing mechanisms in humans? 


Sugar alcohols can elevate blood glucose, insulin levels, and fat-storage in adipose tissue fat cells, despite what manufacturers claim. 


Food manufacturers should not be allowed to use the terms "Low Carb" or "Net Carb" foods until there is definitive data showing the clinical response of all raw materials used in food manufacturing, such as sugar alcohols. 


Only specific laboratory and definitive clinical studies can quantify these terms. If manufacturers are allowed to state "Net Carbs" without clinical evidence of the biochemical properties of foods and raw materials, there will be mis-labeling, misuse, and outright fraud against the public. 


All carbs and sugars and sugar alcohols present caloric value, as well as blood glucose, insulin, and fat-storage properties. 


It is our position that all carbohydrates and sugars should be claimed under Carbohydrates, and not allowed to be placed under the guise of "Low Carb" or "Net Carb." 


Dr. Ann de Wees Allen 
Chief of Biomedical Research 
Glycemic Research Institute Washington, D.C.

United States 
Department of Agriculture

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