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| ![](me          | **Citrus**                   | > **(209)          |
| dia/image1.png) |                              | > 738-0246**       |
| {width="1.85in" | **Research**                 | >                  |
| hei             |                              | > **Fax (209)      |
| ght="1.5375in"} | **Board**                    | > 738-0607**       |
|                 |                              | >                  |
|                 |                              | > **E-Mail:        |
|                 |                              | > <C               |
|                 |                              | itrusRB@aol.com>** |
|                 |                              | >                  |
|                 |                              | > **323 W. Oak**   |
|                 |                              | >                  |
|                 |                              | > **P.O. Box 230** |
|                 |                              | >                  |
|                 |                              | > **Visalia, CA    |
|                 |                              | > 93279**          |
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August 20, 2002

Dockets Management Branch (HFA-305)

Food and Drug Administration

5630 Fishers Lane, Room 1061

Rockville, MD 20852

> **REGARDING: DOCKET NO. 01N-0548**
>
> Food Labeling; Guidelines for Voluntary Nutrition Labeling of Raw
> Fruits, Vegetables, and Fish; Identification of the 20 Most Frequently
> Consumed Raw Fruits, Vegetables, and Fish. 67 FR 12918, March 20,
> 2002.

Dear Sir or Madam:

The Citrus Research Board is a commodity program established under the
California Marketing Act, which enables the state's citrus growers to
sponsor and support research and to promote quality assurance throughout
the industry. Growers voted by referendum to create this marketing order
in 1968, and they have reaffirmed their support of the program in
continuation referendums conducted every 5 years. In administering the
program, the Citrus Research Board has the responsibility of determining
the industry\'s most important needs related to research, including
nutrient composition research on citrus fruits.

The Citrus Research Board appreciates the opportunity to offer the
following comments on the proposed Guidelines for Voluntary Nutrition
Labeling of Raw Fruits, Vegetables, and Fish.

[Data to Use in the Nutrition Labeling of Oranges, Grapefruit,
Tangerines, and Lemons]{.underline}

For oranges and grapefruit, we urge the agency to combine data submitted
recently by USDA and by the Citrus Research Board. USDA's data on
vitamin C, sodium, and potassium should also be incorporated as soon as
it is available.

There is no significant difference in values between the USDA market
basket data and the Citrus Research Board packinghouse data.

For lemons and tangerines (i.e. Mandarins), we recommend combining the
data submitted recently by the Citrus Research Board with existing data
from the Produce Marketing Association.

If the data are weighted, the weighting should be by season and by
variety.

[Total Carbohydrate Should Be Calculated by Difference]{.underline}

Total carbohydrate should not be adjusted to accommodate a sugars value
that is from a different source (i.e. USDA Home Economics Research
Report No. 48 "Sugar Content of Selected Foods: Individual and Total
Sugars").

21 CFR 101.9(c)(6) states, "Total carbohydrate content shall be
calculated by subtraction of the sum of the crude protein, total fat,
moisture, and ash from the total weight of the food." The regulation
cites USDA Handbook No. 74, *Energy Value of Foods---Basis and
Derivation* (slightly revised, 1973), by Merrill, AL and Watt, BK (pp.
2-3).

This method of determining total carbohydrate content is accepted and
used universally (see Attachment 1 for additional references in support
of this method).

[Fat Content of Citrus Fruits]{.underline}

We believe that any analytical data that does not support a zero fat
value for citrus fruits is the result of improper sample preparation in
which the inedible seeds were not removed before analysis. Any
detectable amount of fat is contained in the seeds, which are refuse,
and should not be considered to be part of the edible portion of citrus
fruits. The label values for fat and calories from fat should be zero on
all citrus fruit.

Thank you for the opportunity to comment on these important Guidelines.

Sincerely yours,

Citrus Research Board

Ted A. Batkin

President

**ATTACHMENT 1**

**References for Total Carbohydrate Calculations**

**Code of Federal Regulations 21 CFR 101.9**

"Total carbohydrate content shall be calculated by subtraction of the
sum of the crude protein, total fat, moisture, and ash from the total
weight of the food" \[101.9(c)(6)\]. The regulation cites USDA Handbook
No. 74, Energy Value of Foods---Basis and Derivation (slightly revised,
1973), by Merrill, AL and Watt, BK (pp. 2-3).

**USDA Nutrient Database for Standard Reference, Release 14 (SR 14,
2000)**

"Carbohydrate, when present, was determined as the difference between
100 and the sum of the percentages of water, protein, total lipid (fat),
ash, and, when present, alcohol. Total carbohydrate values include
fiber."

Note: SR 14 does not incorporate sugars values from Sugar Content of
Selected Foods (HERR No. 48). When available, data on individual sugars
(determined by HPLC or GC) are included. "Total sugars" is reported as
the sum of mono- and disaccharides.

**Covance Laboratories**

Total carbohydrate is calculated by difference (sum of protein, fat,
water, and ash, subtracted from total weight). The following reference
is cited: *Composition of Foods*, Agriculture Handbook #8 (1963), USDA
(pp. 164-65).

**AOAC International**

"Total carbohydrate content is calculated by subtraction of the sum of
the crude protein, total fat, moisture, and ash from the total weight of
the food." *Methods of Analysis for Nutrition Labeling* (1993),
Sullivan, DM and Carpenter, DE, Eds., Arlington, VA: AOAC International
(p. 8).