Contains Nonbinding Recommendations 
Guidance for Industry 
Acrylamide in Foods 
Additional copies are available from: 
Office of Food Safety, HFS-300 
Center for Food Safety and Applied Nutrition 
Food and Drug Administration 
5001 Campus Drive
College Park, MD 20740  
(Tel) 240-402-1700  
http://www.fda.gov/FoodGuidances 
You may submit either electronic or written comments regarding this guidance at any time.  
Submit electronic comments to http://www.regulations.gov. Submit written comments on 
the guidance to the Division of Dockets Management (HFA-305), Food and Drug 
Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. All comments should 
be identified with the docket number [FDA2013D0715] listed in the notice of 
availability that publishes in the Federal Register.  
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Food Safety and Applied Nutrition 
March 2016    Contains Nonbinding Recommendations 
Table of Contents 
I.  Introduction
II.  Background
III.  Discussion
A.  General comments 
B.  Potato-based foods 
i.  Raw materials 
ii.   Processing and ingredients 
a.  French fries 
b.  Sliced potato chips 
c.  Fabricated potato chips and other fabricated potato snacks 
C.  Cereal-based foods 
i.  Raw materials 
ii.  Processing and ingredients 
D.  Other foods 
E.  Preparation and cooking instructions on packaged frozen french fries 
F.  Information for food service operations 
IV.  References
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1
Guidance for Industry  
Acrylamide in Foods 
 
This guidance represents the current thinking of the Food and Drug Administration (FDA 
or we) on this topic.  It does not establish any rights for any person and is not binding on 
FDA or the public.  You can use an alternative approach if it satisfies the requirements of 
the applicable statutes and regulations.  To discuss an alternative approach, contact the 
FDA staff responsible for this guidance as listed on the title page. 
 
I. Introduction 
This guidance provides information to help growers, manufacturers, and food service 
operators reduce acrylamide levels in certain foods.  Acrylamide is a chemical that can form 
in some foods during certain types of high-temperature cooking. Reducing acrylamide 
levels in foods may mitigate potential human health risks from exposure to acrylamide.  
This guidance is intended to suggest a range of possible approaches to reducing acrylamide 
levels and not to identify specific recommended approaches.  This guidance also does not 
identify any specific maximum recommended level or action level for acrylamide.  The 
Food and Drug Administration (FDA or we) will update this guidance as needed to reflect 
new developments in the field of acrylamide reduction.  
FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidances describe our current thinking on a topic and should be 
viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited.  The use of the word should in FDA guidances means that something is suggested or 
recommended, but not required.  
II. Background 
In 2002, scientists announced the discovery of the chemical acrylamide in a variety of 
heated foods (Ref. 1).  Further research determined that acrylamide forms in some foods 
during certain types of high-temperature cooking (Refs. 2-3).  Acrylamide in food is a 
concern because it can cause cancer in laboratory animals at high doses, and is reasonably 
anticipated to be a human carcinogen (Ref. 4)2.  In 2010, an international evaluation of 
                                                           
1 This guidance has been prepared by the Division of Plant Products and Beverages, Office of Food 
Safety, in the Center for Food Safety and Applied Nutrition at the U.S. Food and Drug Administration. 
 
2 The complete quotation is Acrylamide is reasonably anticipated to be a human carcinogen based on 
sufficient evidence of carcinogenicity from studies in experimental animals (Ref. 4). The NTP classifies a 
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acrylamide by the WHO/FAO Joint Expert Committee on Food Additives (JECFA) (Ref. 5) 
concluded that acrylamide may be a human health concern.3  JECFAs work was based in 
part on studies conducted by the FDA National Center for Toxicological Research for the 
National Toxicology Program (Ref. 6). 
Acrylamide forms in foods from a chemical reaction between asparagine, an amino acid, and 
reducing sugars such as glucose and fructose. This reaction is part of the Maillard reaction, 
which leads to color, flavor, and aroma changes in cooked foods (Refs. 2-3, 7). Acrylamide 
formation usually occurs at elevated temperatures used when frying or baking (above 120 
C (248 F)) and in low moisture conditions, although acrylamide has also been identified in 
some fruit and vegetable products heated at lower temperatures or higher moisture 
conditions (Refs. 8-11).  Also, acrylamide formation occurs primarily in plant-based foods, 
notably potato products such as french fries and potato chips; cereal- grain-based foods such 
as cookies, crackers, breakfast cereals, and toasted bread; and coffee.  Acrylamide is also 
found in cigarette smoke and is produced industrially for use in products such as plastics, 
grouts, water treatment products, and cosmetics. 
Since the discovery of acrylamide in food, the international research community has 
explored numerous strategies for reducing acrylamide in food products. This work is 
summarized in the scientific literature (Refs. 12-29), as well as in guidance materials 
prepared by industry, other governments, and international organizations.  Notable guidance 
materials include the Acrylamide Toolbox produced by FoodDrinkEurope (Ref. 30) and 
the Codex Alimentarius Code of Practice for the Reduction of Acrylamide in Foods (Ref. 
31).  Other guidance documents include FoodDrinkEurope Toolbox brochures on selected 
foods for small- and medium-sized businesses (Refs. 32-36), reviews of acrylamide 
mitigation produced by the Association of the Chocolate, Biscuits, and Confectionary 
Industries of the European Union (CAOBISCO) (Refs. 37-38), and Guidelines to 
Authorities and Consumer Organisations on Home Cooking and Consumption and Manual 
on Strategies to Food Industries, Restaurants, etc., to Minimize Acrylamide Formation 
produced by the Heat-Generated Food Toxicants: Identification, Characterization and Risk 
Minimisation (HEATOX) Project (Refs. 39-40).  FDA has also published advice for 
consumers on its website (Ref. 41).  This guidance document for industry draws on such 
publications, and FDA encourages manufacturers to review all resources when considering 
their approach to reducing acrylamide levels in their products. 
To obtain additional information, particularly information relevant to the United States, 
FDA published a notice in the Federal Register in August 2009 (74 FR 43134) requesting 
information on practices that manufacturers have used to reduce acrylamide in food and the 
reductions they have been able to achieve in acrylamide levels. 
                                                                                                                                                                                  
substance as reasonably anticipated to be a human carcinogen if, in relevant part, there is sufficient 
evidence of carcinogenicity from studies in experimental animals, which indicates there is an increased 
incidence of malignant and/or a combination of malignant and benign tumors (1) in multiple species or at 
multiple tissue sites, or (2) by multiple routes of exposure, or (3) to an unusual degree with regard to 
incidence, site, or type of tumor, or age at onset (Ref. 4). 
 
3 The complete quotation is The Committee considered that for a compound that is both genotoxic and 
carcinogenic, these [margins of exposure] indicate a human health concern (Ref. 5). 
 
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III. Discussion 
A. General comments 
This guidance suggests a range of possible approaches to acrylamide reduction.  It is not 
intended to identify specific recommended approaches. Acrylamide reduction is an area of 
ongoing research, and some approaches discussed may still be at a research stage, rather 
than in general use. We recommend that manufacturers evaluate approaches that may be 
relevant to their particular processes and consider adopting approaches, if feasible, that 
reduce acrylamide levels in their products.  When evaluating approaches, it is important to 
consider the impact on overall chemical and microbiological safety, nutritional quality, and 
organoleptic properties (Ref. 31).   
Factors affecting acrylamide formation are present at various stages from farm to table, so 
this guidance is for growers, manufacturers, and food service operators.  Sections B, C, and 
D of the guidance cover raw materials, processing practices, and ingredients affecting 
potato-based foods, cereal-based foods, and coffee, respectively. Section E provides 
suggested preparation and cooking instructions on packaged frozen french fries.  Finally, 
Section F informs food service operations of techniques for preparing potato-based and 
cereal-based foods. 
FDA is not suggesting maximum recommended levels for acrylamide in various products at 
this time.  We recommend that manufacturers be aware of acrylamide levels in their 
products, because knowledge of acrylamide levels is essential for determining the 
effectiveness of acrylamide reduction techniques.  The predominant analytical methods for 
acrylamide determination are liquid chromatography/tandem mass spectrometry (LC/MS-
MS) and gas chromatography/mass spectrometry (GC/MS) (Ref. 42). LC/MS-MS and 
GC/MS methods, though highly sensitive, are expensive and time-consuming.  Also, 
because acrylamide can vary significantly between identically prepared products, extensive 
sampling may be required to detect the effects of process changes (Refs. 43-44).  One 
approach to reducing analytical testing (e.g., by LC/MS-MS and GC/MS) is to identify a 
characteristic that can be monitored as a proxy for acrylamide, such as color or moisture, 
and calibrate variation in this characteristic to analytically determined acrylamide levels. To 
be effective, such analysis may have to be performed on a product by product basis. 
Methods other than LC/MS-MS and GC/MS, such as immunoassays (Refs. 45-49), also 
have been proposed.  FDA has monitored acrylamide levels in foods in the U.S. (Refs. 10-
11) and conducted exposure assessments of U.S. consumers (Ref. 50).  FDA will continue to 
monitor acrylamide levels in food to determine, in part, if reductions in acrylamide occur 
over time. 
B. Potato-based foods 
i. Raw materials 
In potatoes, reducing sugars are present in excess compared with asparagine, and reducing 
sugar levels are the important factors driving acrylamide formation.  Careful control of 
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reducing sugar levels can reduce acrylamide formation in finished potato products such as 
french fries and potato chips.  Among the factors that affect reducing sugar levels are potato 
variety, growing and harvesting practices, maturity, handling, and storage conditions 
(including temperature and control of sprouting). 
Varieties.  French fry and potato chip producers have traditionally selected potatoes that are 
low in reducing sugars to minimize browning.  Chipping potatoes (for potato chips) typically 
have the lowest sugar levels, followed by potatoes for french fry processing, and fresh 
market potatoes (Ref. 51).  Selecting potato varieties that are as low as possible in reducing 
sugars may help reduce acrylamide, while still retaining desirable product qualities.  Some 
members of the Snack Foods Association (SFA) recommend against using Russet varieties 
for producing potato chips because of high reducing sugar levels (Ref. 44). 
Typically, manufacturers use different potato varieties throughout the year, depending on 
whether the potatoes are coming from fresh crops or from storage. The most suitable variety 
may vary by region and by season.  Large manufacturers may be able to specify suitable 
varieties or grow their own varieties through contracts.  Smaller manufacturers may be able 
to consult with local extension services to identify low-reducing-sugar potato varieties 
available in their region at different times of the year, or request their suppliers to provide 
low-reducing-sugar varieties, when possible. 
New potato varieties with lower reducing sugar content and greater resistance to cold-
induced sweetening are in development, as are cultivars with lower levels of asparagine 
(Refs. 30, 52, 53).  Both conventional breeding (e.g., crossing commercial potato varieties 
with wild varieties) and biotechnology have shown promise in reducing acrylamide levels. 
Six new bioengineered potato varieties with lower asparagine and/or reducing sugar levels 
and lower acrylamide formation potential have completed FDAs final biotechnology 
consultation process (Ref. 54). Development and commercialization of new potato varieties 
is a lengthy process, but may ultimately provide the most effective solution for acrylamide 
reduction.  As new potato varieties come on the market, consider adopting varieties that 
offer the potential to reduce acrylamide levels. 
Summary: Selecting potato varieties that are low in acrylamide precursors, keeping in 
mind seasonal variation, may help reduce acrylamide. 
Growing and harvesting practices.  Immature potato tubers have higher reducing sugar 
levels (Refs. 20, 43-44), and use of mature tubers has been associated with lower acrylamide 
levels in cooked potatoes (Ref. 55).  Growers can optimize potato maturity at time of harvest 
by controlling planting time and input management (Ref. 44).  There is some evidence that 
increasing fertilization with potassium or avoiding excessive fertilization with nitrogen can 
hasten maturation and result in lower sugar levels at harvest or after harvest (Refs. 20, 29).  
Some data suggest that use of earlier maturing varieties, selecting growing sites where 
harvests can be delayed, and maintaining continued irrigation to avoid growth interruptions 
may also assist in managing maturity (Ref. 20).  An optimal maximum sucrose level of 1.5 
mg/g at harvest has been recommended by some as an indicator of maturity in chipping 
potatoes intended for storage (Refs. 20, 56), although the optimal sucrose level depends on the 
product and the process (Ref. 57).  After harvest, manufacturers should avoid immature 
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tubers by selecting, sorting, or grading potatoes before processing (Ref. 31). 
Summary: Optimizing potato maturity by controlling planting time, harvest time, and 
input management, and by removing immature tubers before processing, may help 
reduce acrylamide. 
Defects and bruising.  Both potato defects and bruising of potatoes during harvesting and 
handling can be associated with increased levels of acrylamide in products (Ref. 44). 
Avoiding handling potatoes with excessive roughness, avoiding bruising potatoes, and 
sorting out or carefully trimming potatoes with defects may help reduce acrylamide. 
Summary: Avoiding handling potatoes with excessive roughness, avoiding bruising 
potatoes, and sorting out or carefully trimming potatoes with defects may help reduce 
acrylamide. 
Cold temperatures during harvest, transport, delivery, and storage.  Potatoes exposed to 
sustained cold temperatures can undergo cold sweetening, i.e., develop higher levels of 
reducing sugars in response to cold.  Temperature, among other factors, can be considered 
when determining harvest times (Ref. 58).  Avoiding sustained cold temperatures during 
transport and delivery for processing or storage could reduce acrylamide (e.g., avoid leaving 
potato deliveries outside in freezing conditions) (Ref. 31). 
Potatoes are stored through the fall, winter, and spring to provide a steady source of potatoes 
for processing throughout the year.  Storage is typically in temperature- controlled, 
humidity-controlled, ventilated storage facilities.  Trade associations recommend 
temperatures greater than 43 F for long-term storage of potatoes used for potato chips or for 
french fries (Refs. 30, 44).  Some guidelines recommend higher temperatures (e.g., near 50 
F or greater for chipping potatoes (Refs. 51, 59) or 47-50 F for french fry processing (Ref. 
51)). 
Summary: Avoiding cold temperatures during harvest, transport, delivery, and 
storage may help reduce acrylamide. 
Storage and Sprouting. Potatoes in long-term storage will begin to sprout after a dormant 
period if sprout production is not suppressed, e.g., by use of chemicals or controlled 
temperature storage.  Sprouting can lead to conversion of stored starch to sugars (Ref. 43), 
increasing potential for acrylamide formation and excessive browning in cooked products. 
Therefore, some guidelines recommend the use of sprout suppressants, following good 
agricultural practices (Ref. 30). 
Insufficient storage ventilation leading to oxygen starvation of potatoes has also been 
associated with increased sugar levels (Ref. 51).  Potential causes of insufficient oxygen 
availability include infrequent operation of the ventilation system or excess dirt on potatoes 
(Ref. 51). 
Summary: Managing storage conditions to control sprouting and provide 
ventilation may help reduce acrylamide. 
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Reconditioning.  Potatoes that have higher reducing sugar levels due to exposure to cold 
temperatures during storage may be reconditioned at warmer temperatures (e.g., at 
temperatures around  60 F (Ref. 60) or at ambient temperatures (Ref. 30)) to encourage 
the conversion of reducing sugars back into complex carbohydrates.  Sprouting may be 
avoided by using reconditioned potatoes relatively soon after reconditioning (Ref. 60). 
Acrylamide could be reduced by avoiding using potatoes that have been in storage for 
prolonged periods after which cold sweetening may be difficult to reverse (Refs. 20, 44), 
although some potato varieties can remain in storage longer than others without 
development of reducing sugars (Ref. 57).  Monitoring reconditioning by measuring 
reducing sugar levels or conducting fry tests may also help reduce acrylamide (see below).   
Summary: Monitoring reconditioning results and avoiding reconditioning potatoes 
stored for prolonged periods may help reduce acrylamide. 
Screening incoming potatoes. Reducing sugar levels can be assessed in incoming potatoes 
by sugar measurements or fry tests.  Fry tests, a method used on French fries, typically 
consist of frying freshly cut potato strips for 3 minutes at approximately 360 F (182 C), 
and comparing the fried strips to the USDA Color Standards for Frozen French Fried 
Potatoes, based on such factors as overall color and brightness, sugar ends, and sugar 
tips (Refs. 43, 61).  Manufacturers may find it helpful to use a colorimeter.  Checking 
color after test strips have been blanched, par-fried, and final fried may also be useful, 
since this treatment more closely mirrors the typical fry production process (Ref. 61).  
Darker fry test results or high reducing sugar levels correlate with finished products that 
will brown too strongly and have higher acrylamide levels. 
U.S. producers of frozen french fries and sliced potato chips have not recommended a 
target reducing sugar level for incoming potatoes (Refs. 43-44).  According to the Frozen 
Potato Products Institute (FPPI), french fry manufacturers typically establish grower 
incentives to provide potatoes with as low a reducing sugar level as feasible, rather than 
specifying levels (Ref. 43).  Incoming potatoes with undesirably high sugar levels can also 
be subjected to additional treatments, such as reconditioning and blanching, to reduce 
sugar levels before high temperature cooking processes (Ref. 31). 
The Acrylamide Toolbox recommends selecting potato varieties with low reducing sugars 
that are suitable for the product type (Ref. 30).  However, for color control, the University 
of Idaho has recommended that glucose levels be less than 0.35 mg/g (0.035 percent) 
fresh tuber weight for chipping potatoes and less than 1.2 mg/g (0.12 percent) for french 
fries (Ref. 51) (glucose numbers can be doubled to approximate total reducing sugar 
levels (Ref. 43)). 
Summary: Assessing reducing sugar levels in incoming potatoes, identifying target 
levels for incoming potatoes, or using treatments to reduce sugar levels may help 
reduce acrylamide. 
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Table 1: Summary for POTATOES: Raw materials 
  Selecting potato varieties that are low in acrylamide precursors, keeping in mind 
seasonal variation, may help reduce acrylamide. 
  Optimizing potato maturity by controlling planting time, harvest time, and input 
management, and by removing immature tubers before processing, may help 
reduce acrylamide. 
  Avoiding handling potatoes with excessive roughness, avoiding bruising potatoes, 
and sorting out or carefully trimming potatoes with defects may help reduce 
acrylamide. 
  Avoiding cold temperatures during harvest, transport, delivery, and storage may 
help reduce acrylamide. 
  Managing storage conditions to control sprouting and provide ventilation may help 
reduce acrylamide. 
  Monitoring reconditioning results and avoiding reconditioning potatoes stored for 
prolonged periods may help reduce acrylamide. 
  Assessing reducing sugar levels in incoming potatoes, identifying target levels for 
incoming potatoes, or using treatments to reduce sugar levels may help reduce 
acrylamide. 
ii. Processing and ingredients 
 
This section reviews the processing of french fries, sliced potato chips, fabricated potato 
chips, and other fabricated potato snacks. 
 
a. French fries.  In the U.S., french fries supplied to foodservice establishments and 
packaged for direct sale to consumers are typically frozen, par-fried french fries.  A 
standard production process for frozen, par-fried french fries consists of peeling, 
washing, sorting for size and defects, cutting or slicing, blanching, dipping or coating 
(e.g., in a dextrose solution), drying, and par-frying.  The par-fried products are 
intended to be cooked to completion in a food-service establishment or in the 
consumers home.  Levels of acrylamide are low in the par-fried fries, but increase 
significantly in the final cooked product.  Final cooking conditions are the major factor 
in determining final acrylamide levels, but changes in processing by frozen french fry 
manufacturers can also affect acrylamide levels in the final product (Ref. 43). 
 
Sorting.  See the discussion on choosing potato varieties and screening potatoes in Section 
III.B.i. 
 
Cutting.  Acrylamide formation is typically higher in the surface layer or crust of foods 
than in the inside; therefore, decreasing product surface area relative to volume may 
decrease acrylamide in cooked french fries.  For frozen french fries, cutting thicker 
strips or shapes with lower surface area may reduce acrylamide (Refs. 31, 62).  Cutting 
potato rings that avoid inner core material may also lower acrylamide compared to 
straight cut fries (Ref. 63). 
 
Smaller or thinner potato pieces have a greater surface area to volume ratio than larger 
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pieces, and produce more acrylamide on a volume basis (Refs. 29, 30-31).  Screening to 
remove nubbins  (short strips) and slivers (thin strips) may reduce acrylamide. 
Optimization of cutting practices may be useful in limiting production of small fragments 
(Ref. 64). 
 
Summary: Cutting fries in shapes with lower surface area to volume ratio and 
screening out small fragments may help reduce acrylamide. 
 
Blanching.  Manufacturers of frozen french fries routinely blanch raw potato strips in hot 
water or steam before par-frying.  Blanching can provide more uniform color after frying, 
inactivate enzymes, and form a layer of gelatinized starch that limits oil absorption and 
improves fry texture (Refs. 65-66).  Blanching also removes reducing sugars and 
asparagine from the potato surface, decreasing acrylamide in fries (Ref. 30).  
Modifications to blanching processes, such as changes in time and temperature, may help 
reduce acrylamide, although such modifications may affect product quality.  For example, 
one research study found that shorter blanching times at high temperatures were more 
effective at acrylamide reduction than longer low-temperature blanches (Ref. 65). 
 
Summary: Changing blanching practices may help reduce acrylamide, although 
such changes may affect product quality. 
 
Dips and coatings.  For foodservice fries, blanching may be followed by dipping in a 
dextrose solution to replace sugars removed during blanching and provide uniform 
coloration (Ref. 43).  Initial recommendations called for avoiding the use of sugar 
solutions as a browning agent or a coating (Ref. 31).  However, french fries produced by 
blanching and dipping in a dextrose solution may show less variability in acrylamide 
levels and reduced acrylamide compared with fries that rely on naturally present sugars 
for color, flavor, and aroma development (Ref. 67).  With less variability, manufacturers 
may find it easier to identify treatments that are effective in mitigating acrylamide in 
industrial processes (Ref. 67).  Dipping with fructose should be avoided (Ref. 68). 
 
Summary: Using sugar dips to reduce variability may help reduce acrylamide, but 
using reducing sugars such as fructose in dips may increase acrylamide. 
 
One approach used by manufacturers to reduce acrylamide formation in oven-baked frozen 
french fries is to add a food-grade coloring agent such as annatto (Refs. 30, 43).  The darker 
color may improve product appearance and discourage over-baking by the consumer, which 
can increase acrylamide levels. 
 
Summary: Using alternative coloration methods may help reduce acrylamide by 
discouraging over-baking. 
 
Addition of sodium acid pyrophosphate (SAPP) during blanching (Ref. 31) or in a dip 
after blanching (Ref. 30) is standard industry practice to prevent darkening of uncooked 
potato fry strips (Ref. 30).  Treatment with SAPP also reduces acrylamide (Ref. 30), 
presumably by acidifying the surface of potatoes (Refs. 30, 31, 69).  However, SAPP 
may cause off flavors at levels higher than current industry usage (Ref. 43).  Current 
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industry usage is approximately 0.5 to 1.0 percent SAPP (Ref. 70). 
 
Some french fries are dipped before frying in batter coatings containing flours, starches, 
hydrocolloids, or other ingredients to improve texture, flavor, structure, and heat 
retention (Refs. 71-72).  Some batters may reduce acrylamide formation (Ref. 73), but 
Codex (Ref. 31) recommends examining batter ingredients to ensure there are no 
ingredients that can increase acrylamide formation in final fried products. 
 
Summary: Using SAPP may help reduce acrylamide, as may evaluating other dip or 
batter ingredients to determine if they contribute to acrylamide formation during 
frying. 
Table 2: Summary for POTATOES: Processing french fries 
 
 Cutting fries in shapes with lower surface area to volume ratio and screening out small 
fragments may help reduce acrylamide. 
 Changing blanching practices may help reduce acrylamide, although such changes may 
affect product quality. 
 Using sugar dips to reduce variability may help reduce acrylamide, but using reducing 
sugars such as fructose in dips may increase acrylamide. 
 Using alternative coloration methods may help reduce acrylamide by discouraging over-
baking. 
 Using SAPP may help reduce acrylamide, as may evaluating other dip or batter 
ingredients to determine if they contribute to acrylamide formation during frying. 
Other considerations 
 
The following section summarizes information on possible acrylamide reduction techniques 
for french fries that have produced ambiguous results, and therefore may have not been 
successfully implemented on an industrial scale. 
 
Treatment with cations4.  Treatment of potato strips (french fries) with calcium salts or 
sodium chloride before frying decreased acrylamide significantly in laboratory studies (Refs. 
30, 74-75), but treatment with calcium lactate gave poor results on an industrial scale (Ref. 
30).  Calcium use may cause hard texture and off tastes in fries, and may not be compatible 
with SAPP use (Ref. 30).  Manufacturers may be reluctant to add sodium for nutritional 
reasons. 
 
Treatment with acidulants5.  Acidulants (acetic acid, ascorbic acid, citric acid, monosodium 
citrate, sodium citrate, lactic acid, lactic acid bacteria) effectively suppress acrylamide 
formation in laboratory model systems and in fried potato products, including french fries 
(Refs. 13, 18, 30, 43, 69, 76-79).  However, they can also cause a sour or tart taste (Refs. 18, 
30, 43), suppress development of other flavors (Ref. 30), and potentially cause corrosive 
                                                           
4 A positively charged ion such as calcium (Ca+2), magnesium (Mg+2), or sodium (Na+). 
5 Acidulants are chemicals that are added to food to increase acidity. 
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effects on production equipment (Ref. 30).  In a manufacturing trial, treatment with citric 
acid and acetic acid did not provide additional acrylamide reduction compared with standard 
practices (Ref. 30). 
 
Treatment with amino acids.  Amino acids6 (e.g., glycine, lysine, cysteine, taurine) reduced 
acrylamide in potato model systems (Ref. 18) and in potato pieces (Ref. 80) and potato slices 
(Refs. 69, 81) in laboratory studies.  However, glycine reportedly caused excessive 
browning and bitter flavor in finished potato products (Ref. 43) and was ineffective when 
tested on french fries in laboratory studies (Ref. 30).  The amino acid cysteine reportedly 
caused unpleasant odors in potato model systems (Refs. 18, 82-83).  
 
Treatment with asparaginase.  Asparaginase is an enzyme that breaks down asparagine to 
aspartic acid and ammonia, preventing asparagine from reacting with sugars to form 
acrylamide.  Four asparaginase preparations with different pH and temperature optima have 
undergone the GRAS notification process in the U.S., and are currently available for 
commercial use in foods (Refs. 84-89).  Some success has been reported with asparaginase 
treatment in french fries and other cooked potato products in laboratory trials and pilot plant 
studies (Refs. 18, 85, 90).  The effectiveness of asparaginase in reducing acrylamide in the 
finished product has been shown to increase when the raw material is blanched prior to 
enzyme application (Refs. 28, 85).  However, the 2013 edition of the Acrylamide Toolbox 
reported that asparaginase produced inconsistent reductions in acrylamide in industrial trials 
of frozen parfried french fries and depended on conditions when the enzyme was applied 
(Ref. 30).  Asparaginase was effective in reducing acrylamide in finished products when 
used on non-parfried blanched, chilled potato strips, as the longer contact time between the 
enzyme and asparagine resulted in asparagine depletion (Ref. 30).  Potential barriers 
identified by industry to the use of asparaginase in french fry production include costs of the 
enzyme and adaptation of manufacturing lines (Ref. 43); effects on flavor resulting from 
asparagine depletion (Ref. 43); different optimal temperatures and pH for asparaginase 
activity and other processes, e.g., SAPP treatment (Refs. 30, 43); and the potential for 
microbial growth in solutions held at temperatures optimal for asparaginase (Ref. 43). 
 
Other ingredients.  Some studies have identified a number of other ingredients that reduced 
acrylamide formation in laboratory studies in french fries or other potato products, including 
plant extracts (Refs. 91-92), hydrocolloids (Ref. 73), vitamins (Ref. 93), antioxidants, and 
spices (Ref. 18).  The efficacy of these compounds in finished food products is not clear 
(Ref. 18).  For new ingredients, it is important to consider such factors as impact on 
moisture content (Ref. 44), sensorial quality, nutritional quality, regulatory status, and 
potential formation of byproducts. 
 
b. Sliced potato chips.  A typical production process for sliced potato chips consists of 
peeling, washing (and/or blanching), slicing, frying, sorting, seasoning, and packaging. 
 
Peeling.  Abrasive peeling is typically used in the potato chip industry.  Peeling chipping 
potatoes more than what is typical for chip preparation can decrease acrylamide levels in the 
finished chips because reducing sugar levels may be higher near the peel (Refs. 30, 44).  
                                                           
6 Amino acids are molecules that combine to form proteins. 
 
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Trials of hot steam peeling as an alternative to abrasive peeling indicate that it may increase 
acrylamide levels in potato chips (Ref. 44), depending on potato variety and season (Refs. 
30, 57).  
 
Summary: Increasing peel removal may help reduce acrylamide. 
 
Sorting.  See the discussion on choosing potato varieties and screening potatoes in 
Section III.B.i. 
 
Washing/Soaking/Blanching.  Potato slices typically are washed in ambient temperature 
water before frying (Ref. 94), or they may be blanched optionally (Ref. 95).  Water can 
extract acrylamide precursors from potatoes, thereby decreasing acrylamide production in 
fried slices.  Prolonged soaking and higher temperature conditions lead to greater extraction 
of acrylamide precursors and decreased production of acrylamide (Refs. 18, 65).  However, 
excessive soaking can affect organoleptic qualities (e.g., taste, mouth feel).  Some members 
of the SFA concluded that washing potato slices with warm water reduces acrylamide levels 
to a modest extent, but also significantly affects quality and operating costs (Ref. 44), while 
the Acrylamide Toolbox (Ref. 30) concluded that washing has had variable success in chips 
in laboratory and pilot trials, but that blanching is not a desirable mitigation technique 
because it leads to loss of flavor, loss of texture, and increased oil uptake. 
 
Summary: Washing or soaking potato chips before frying may help reduce acrylamide, 
but may cause unacceptable changes to some chips. 
 
Slicing.  Decreasing the slice thickness of potato chips may reduce their acrylamide 
content. The observed effect is opposite that seen for french fries (where thicker slices 
have lower acrylamide), due to the low moisture and fry temperature profile of finished 
potato chips.  Thinner slices may require less thermal input to remove moisture from the 
finished chip than thicker slices, thereby reducing the level of acrylamide formed (Refs. 
30, 57). 
 
Summary: Cutting thinner potato chip slices may help reduce acrylamide. 
 
Thermal input.  Higher temperatures and longer cooking times can increase acrylamide 
formation in potato chips.  In particular, acrylamide formation increases at the end of the 
frying process, as moisture content falls, e.g., below 3 percent (Refs. 27, 94).  
 
One approach to decreasing thermal input is to decrease frying temperatures, while 
increasing the amount of time chips are in the fryers (Ref. 44).  Some U.S. potato chip 
manufacturers have adopted recommendations (Ref. 18) to set fryer temperatures to 175 C 
(347 F) or below, depending on the product and the frying system (Ref. 44).  Resulting 
chips have higher moisture levels and lighter color than previous chips (Ref. 44).  Frying at 
lower temperatures (e.g., below 170 C (338 F)) may cause higher fat uptake and affect 
crispness (Refs. 18, 44). 
 
Moisture levels in finished products are an important consideration (Refs. 18, 30, 44). 
Targeting higher moisture endpoints in sliced potato chips (1.3 to 1.5 percent, depending on 
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the product) can result in reduced acrylamide (Ref. 44).  Moisture levels that are higher 
(e.g., greater than 1.5 %) may affect flavor, texture, and shelf life (Refs. 30, 44), though 
some of these effects may be offset by other changes, such as in packaging.  When 
evaluating proposed mitigation techniques, it is important to consider the moisture level of 
finished products (Refs. 18, 44).  In some cases, mitigation techniques may appear to lower 
acrylamide, while actually raising product moisture to an unacceptable level (e.g., one that 
increases the rate at which products will become stale) (Refs. 44, 94). 
 
Summary: Decreasing frying temperatures to 175 C (347 F) or below and targeting 
higher moisture endpoints may help reduce acrylamide, but it is important to 
determine if moisture endpoints provide acceptable product quality. 
 
Flash frying7 with rapid cooling and vacuum frying8 may be useful approaches for reducing 
acrylamide levels for some manufacturers (Ref. 30).  Vacuum frying may reduce acrylamide 
formation significantly without significant changes in organoleptic properties (Ref. 18).  
However, FoodDrinkEurope reports that vacuum frying may not provide the desired product 
attributes, and may have limited throughput capacity (Ref. 30). 
 
It also may be helpful to use a multi-stage cooking process, in which higher temperatures are 
applied initially, followed by lower temperatures (e.g., below 120 C / 250 F (Ref. 94)) near 
the end of the cooking process when moisture levels are lower and the products are more 
susceptible to acrylamide formation.  The lower temperatures may be applied in this 
second stage using oven-drying (Refs. 94, 96) or vacuum frying (Ref. 94).   
 
Similarly, lower temperatures may occur in batch frying when making kettle chips (Refs. 44, 
57).  Some members of SFA report that changing the thermal input (e.g., time and 
temperature) during batch frying of kettle chips may be the most effective way to reduce 
acrylamide, specifically, by lowering the initial temperature from 310 F (+/- 5 F) to 295 
F (+/- 5 F) (i.e., from 154 C to 146 C), lowering drop temperature to 250 F (121 C) 
after 3 minutes, and lowering the exit temperature at the end of the batch process by a 
comparable amount (Ref. 44). 
 
Summary: Using lower temperatures during final cooking stages and using techniques 
like flash frying, vacuum frying, or batch frying may help reduce acrylamide. 
 
Color and sorting.  Optical sorting of finished chips can remove browned chips, burned 
chips, and chips made from bruised or defective potatoes (Refs. 30, 31, 44). All of these 
defects can indicate chips that have higher acrylamide levels (Ref. 44).  Generally, finished 
chips should be a light golden color or a golden yellow color (Refs. 30, 44).  One 
manufacturer reported using Hunter color measurement for fabricated potato chips, with a 
target L value of 59 to 68 and an a value of 3 to 6 (Ref. 44).9   It is important to correlate 
measured levels of acrylamide in chips with finished product color to have a rough indicator 
of acrylamide levels.  To be useful, such correlations may have to be established for 
                                                           
7 Frying at high temperatures for short periods of time. 
8 Frying under reduced atmospheric pressure to allow use of a lower oil temperature. 
9 On the Hunter L, a,b color scale, L is an indicatory of lightness of color and a is an indicator of position 
of the color on a red-green color axis (http://www.hunterlab.com/pdf/color.pdf). 
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    Contains Nonbinding Recommendations 
individual potato varieties and individual products. 
Summary: Sorting by color may help reduce acrylamide, by providing a useful 
indicator of acrylamide levels, especially if correlated with measured levels of 
acrylamide in specific products. 
Table 3: Summary for POTATOES: Processing sliced potato chips 
 
 Increasing peel removal may help reduce acrylamide. 
 Washing or soaking potato chips before frying may help reduce acrylamide, but may 
cause unacceptable changes to the chips. 
 Cutting thinner potato chip slices may help reduce acrylamide. 
 Decreasing frying temperatures to 175 C (347 F) or below and targeting higher moisture 
endpoints may help reduce acrylamide, but it is important to determine if moisture 
endpoints provide acceptable product quality. 
 Using lower temperatures during final cooking stages and using techniques like flash 
frying, vacuum frying, or batch frying may help reduce acrylamide. 
 Sorting by color may help reduce acrylamide, by providing a useful indicator of 
acrylamide levels, especially if correlated with measured levels of acrylamide in specific 
products. 
 
Other considerations 
The following section summarizes information on proposed acrylamide reduction 
techniques for sliced potato chips that have produced ambiguous results, and therefore may 
have not been successfully implemented on an industrial scale. 
Treatment with cations.  There are conflicting reports on the effectiveness of cations in 
potato chips.  In laboratory trials, treatment with calcium chloride or calcium lactate 
decreased acrylamide in potato chips (Refs. 18, 69); however, the SFA (Ref. 44) reported 
that calcium chloride treatment was not effective or negatively affected potato chip quality.  
On the other hand, the Acrylamide Toolbox (Ref. 30) reported that calcium-treated chips 
had acceptable sensory quality compared with non-treated chips, but noted that sensory 
quality must be confirmed in treated chips with the same moisture content as non-treated 
chips, particularly since calcium treatment has been linked to brittleness and off flavors 
previously (Ref. 30).  Sodium chloride also reduced acrylamide levels in laboratory trials 
(Ref. 97).  A potential concern with sodium chloride treatment is increased sodium intake, 
although the amount of sodium needed to affect acrylamide may be less than is normally 
present in salted chips at retail (Ref. 69). 
 
Treatment with acidulants.  In laboratory trials, treatment with acidulants decreased 
acrylamide levels in sliced potato chips (Refs. 69, 78).  According to the SFA (Ref. 44), 
treatment of sliced potato chips with the acidulants phosphoric acid and citric acid was not 
effective or negatively affected chip quality.  However, others have reported that acrylamide 
reductions can occur at acid concentrations that provide good sensory quality (Ref. 69).  
Combinations of acidulants and amino acids (Ref. 69) have also been reported to be 
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    Contains Nonbinding Recommendations 
effective at reducing acrylamide in potato chips.  Sensory effects may be variable depending 
on the product (Ref. 30). 
 
Treatment with amino acids.  In laboratory trials, treatment of potato slices with certain 
amino acids (glycine, glutamine) in a blanching step decreased acrylamide levels in potato 
chips (Refs. 69, 98).  Combined treatment with glycine and citric acid was also reported to 
have additive effects in reducing acrylamide in a potato cake model (Refs. 30, 77).  
However, the SFA (Ref. 44) reported that several manufacturers testing L-cysteine and other 
amino acids found that they did not have a significant effect on acrylamide in sliced potato 
chips when tested on an industrial scale. 
 
Treatment with asparaginase.  Asparaginase cannot readily pass through cell walls of 
freshly cut potato slices.  Weakening of cell walls by soaking and pre-treatments including 
blanching, application of acidulants, and ultrasound may allow asparaginase to diffuse into 
potato slices and deplete acrylamide precursors (asparagine and reducing sugars), but such 
treatments can also damage the integrity of potato slices and affect chip flavor and texture 
(e.g., Ref. 30).  Furthermore, the SFA reported that sonication10 and pulse vacuum 
infusion11 did not increase the efficacy of asparaginase treatment (Ref. 44).  Treatment with 
asparaginase in industrial settings has been ineffective and it is not a recommended 
mitigation option for sliced potato chips (Refs. 30, 44). 
 
Other ingredients.  Antioxidants also have been reported to decrease acrylamide in potato 
chips in some laboratory trials (Refs. 18, 91), but the effect of antioxidants on acrylamide in 
laboratory trials has been inconsistent (Ref. 99).  Antioxidants are not addressed by the 
Acrylamide Toolbox or the SFA.  For all ingredients, it is important to consider such factors 
as impact on moisture content, sensorial quality, nutritional quality, regulatory status, and 
potential formation of byproducts. 
 
c. Fabricated potato chips and other fabricated potato snacks 
 
A typical production process for fabricated12 potato chips consists of preparation of a 
dehydrated potato product such as potato flakes or granules, mixing with water and other 
ingredients to form dough, sheeting the dough, cutting, cooking (frying or baking), sorting, 
seasoning, and packaging.  For extruded13 snacks, an extrusion step, with cutting and 
forming operations, follows dough formation.  Some considerations for sliced potato chips 
(see Section III.B.ii.b) also apply to fabricated potato chips or other potato-based snacks.  In 
addition, the following specific information may prove useful. 
 
Potato flakes. Potato flakes are typically made with industry reject or table stock potatoes 
that have high levels of reducing sugar (greater than 2.0 percent) (Ref. 44).  As a result, 
potato flakes tend to be high in reducing sugars, posing mitigation challenges (Ref. 44).  
                                                           
10 Using sound waves to disrupt potato cell walls and allow asparaginase to enter cells. 
11 Using vacuum pulses to infuse substances (e.g., asparaginase) through potato cell walls. 
12 Fabricated products are made from dried potato products (e.g., flakes), rather than fresh potatoes. 
13 Extruded snacks are produced by cooking, pressurizing, and forcing a dough through a die to form a 
unique shape. 
 
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    Contains Nonbinding Recommendations 
Changes in flake purchasing patterns may help with acrylamide management.  The U.S. 
snack industry reports that reducing sugar levels in incoming flakes can range from 0.2 
percent to 2.5 percent, and can vary widely between different shipments (Ref. 44).  One 
option for some snack food manufacturers may be to specify a maximum level of acceptable 
reducing sugars in incoming flakes.  Potato flake supplies bought early in the processing 
season may have lower levels of reducing sugars (Ref. 100).  Also, blending flakes from 
different sources may help reduce variability in sugar levels (Ref. 100). 
 
Changes in flake production also may yield flakes with lower reducing sugar levels. Where 
possible, lower sugar potatoes should be used, but this may not be consistently feasible, 
given current source potatoes (Ref. 44).  Flakes made from fully peeled potatoes may have 
less acrylamide-forming potential than unpeeled or partially peeled potatoes (Ref. 101). 
Treatment with acids or calcium chloride during flake production also may lower 
acrylamide-forming potential (Refs. 44, 101).  The SFA (Ref. 44) reported lower acrylamide 
content in baked potato snacks and fried and baked potato crisps made from calcium-treated 
flakes, with calcium chloride proving more effective than calcium lactate (Ref. 44).  
Acidifying blanch water for potato flake production to pH 4.0  6.5 also reduced acrylamide 
in potato-flake based products by more than 30 percent (Refs. 44, 101).  Problems with 
cooking and drying arose when the pH fell below 4.0, or calcium levels were too high (Ref. 
41).  Some SFA members also reported success combining asparaginase treatment with 
calcium salts during flake production (Ref. 44).  Similarly, an asparaginase manufacturer 
reported a 60 percent reduction in acrylamide in an industrial snack production trial using 
asparaginase-treated potato granules (Ref. 84). 
 
Summary: Selecting potato flakes with lower levels of reducing sugars may help reduce 
acrylamide.  Lower reducing sugar levels may be found by specifying maximum sugar 
levels, buying early in the processing season, or by mixing flakes from different 
sources.  Flakes treated with acidulants, calcium, or asparaginase during flake 
production may also produce flake-based products with lower acrylamide. 
 
Other dough components.  Partial substitution of potato flakes or granules with ingredients 
with lower reducing sugar or asparagine levels (e.g., potato starch or rice) may reduce 
acrylamide formation in fabricated potato snacks (Refs. 14, 31).  Adding fewer reducing 
sugars to the dough (i.e., for flavor) can reduce acrylamide approximately 10 percent (Ref. 
44). 
 
Summary: Partially substituting potato flakes with other ingredients may help reduce 
acrylamide in fabricated potato products. 
 
Treatment with calcium salts.  Addition of calcium salts to doughs is effective in reducing 
acrylamide in fabricated potato snacks (Ref. 30).  Reductions in acrylamide of 30 to 40 
percent in various potato-based snacks and fabricated potato chips have been reported (Refs. 
30, 44, 102).  Calcium addition may be more effective at an acidic pH (Ref. 102).  Potential 
problems, particularly when calcium is in excess, include off flavors and changes in texture 
and color (Refs. 30, 102). 
 
Summary: Adding calcium salts to potato doughs may help reduce acrylamide in 
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    Contains Nonbinding Recommendations 
fabricated potato products. 
 
Treatment with acidulants.  Citric acid and ascorbic acid have been used successfully to 
reduce acrylamide in some fabricated potato products, with no effect on taste (Refs. 30, 44, 
78).  In trials, the impact of citric acid on taste was seen to be product dependent, 
with no effect on some products, but off flavors in others (Ref. 30).  As noted above, 
addition of low levels of acids may improve the efficacy of calcium chloride treatment of 
fabricated products (Refs. 30, 102). 
 
Summary: Adding acidulants to potato doughs may help reduce acrylamide in 
fabricated potato products. 
 
Asparaginase.  Initial reports indicated that asparaginase might not be useful for fabricated 
potato dough products because too much asparaginase was required and resulted in 
significant off flavors and odors from aspartic acid and ammonia byproducts (Refs. 31, 44).  
More recent results indicate that the enzyme can be beneficial for some products, depending 
on recipe and production process (Refs. 30, 84). 
 
Summary: Adding asparaginase to potato doughs may help reduce acrylamide in some 
fabricated potato products. 
 
Thermal input.  For general information, see Section III.B.ii.b above.  This section provides 
additional information on fabricated potato products.  One trade association reported that 
changing thermal input (e.g., time, temperature) may be the most effective way for small 
manufacturers of fabricated potato chips to mitigate acrylamide (Ref. 44). Ideal temperature 
may vary with incoming potato flake sugar content (Refs. 44, 57). This trade association also 
reported that decreasing oven temperature during drying to 123 C (235 F) while increasing 
the drying dwell time reduced acrylamide formation in fabricated potato products (Ref. 44).
 
 
As with sliced potato chips, multistage cooking processes may be helpful in reducing 
acrylamide levels.  Reductions in acrylamide were reported for fabricated potato chips 
prepared by baking or frying in two stages, when the second stage temperature was held 
below 120 C (248 F) (Refs. 94, 103).  In addition, acrylamide can be reduced for 
fabricated chips by setting higher moisture endpoints (Ref. 44). Trade association member 
companies have suggested moisture levels ranging from 1.65 to 2.2 percent for fabricated 
chips (Ref. 44). 
 
Summary: Decreasing cooking temperatures, using lower final temperatures in 
multistage processes, and using higher moisture endpoints may help reduce acrylamide 
in fabricated potato chips. 
 
Color and sorting.  See section III.B.ii.b. 
 
 
Table 4: Summary for POTATOES: Processing fabricated potato chips and other 
fabricated potato snacks 
 
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  Selecting potato flakes with lower levels of reducing sugars may help reduce 
acrylamide.  Lower reducing sugar levels may be found by specifying maximum 
sugar levels, buying early in the processing season, or by mixing flakes from different 
sources.  Flakes treated with acidulants, calcium, or asparaginase during flake 
production may also produce flake-based products with lower acrylamide.  
  Partially substituting potato flakes with other ingredients may help reduce acrylamide 
in fabricated potato products.  
  Adding calcium salts to potato doughs may help reduce acrylamide in fabricated 
potato products.  
  Adding acidulants to potato doughs may help reduce acrylamide in fabricated potato 
products.  
  Adding asparaginase to potato doughs may help reduce acrylamide in some fabricated 
potato products.  
  Decreasing cooking temperatures, using lower final temperatures in multistage 
processes, and using higher moisture endpoints may help reduce acrylamide in 
fabricated potato chips. 
Other considerations 
The following section summarizes information on proposed acrylamide reduction 
techniques for fabricated potato chips and other fabricated potato snacks that have produced 
ambiguous results, and therefore may have not been successfully implemented on an 
industrial scale. 
Amino acids.  Addition of amino acids (e.g., glycine, lysine, and cysteine) shows promise 
for acrylamide reduction in fabricated potato products, based on laboratory and pilot trials 
(Refs. 30, 102, 104).  However, effects on color, taste, and texture from amino acids may be 
a concern if amino acid levels are too high (Ref. 30). 
C. Cereal-based foods 
Cereal-based foods include foods such as bread, crackers, and breakfast cereals that are 
cooked from cereal crops such as wheat and corn.  Section C reviews information on raw 
materials and processing approaches that may reduce acrylamide in cereal-based foods. 
i. Raw materials 
In cereals such as wheat, asparagine is present in excess compared with reducing sugars. 
Therefore, the concentration of asparagine, not reducing sugars, is the important factor 
driving acrylamide formation in cereal-based foods (Refs. 20, 30).  Cereal grain type, grain 
variety, and growing conditions are some of the factors that affect asparagine levels. 
 
Cereal type, cereal variety, and mineral nutrient level.  Asparagine levels vary between 
cereal types, between varieties, and depending on growing year and location.  This 
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variability can significantly impact acrylamide levels in bakery products (Refs. 13, 17, 20, 
30).  Comparing free asparagine levels in different cereal crops, rye has the highest free 
asparagine content, followed by wheat, corn and oats, and then rice (Ref. 20).  Whole grain 
products (e.g., whole wheat) have higher asparagine concentrations than refined grains, and 
produce more acrylamide in finished products (Refs. 20, 30). 
 
Mineral nutrient level is one factor affecting asparagine levels in wheat.  Sulfur deficiency 
can lead to greater asparagine formation, demonstrating the need to maintain sufficient soil 
sulfur levels (Refs. 16, 19-20, 30). Based on studies in the United Kingdom, a minimum of 
15 kg sulfur/hectare14 was recommended for wheat production, along with sufficient 
phosphate and potassium (Ref. 16).  Sulfur deficiency in only part of a total area under 
production (e.g., unfertilized field margins) could potentially cause spikes in asparagine 
levels in certain batches of wheat (Ref. 16).  Excessive nitrogen fertilization may increase 
levels of asparagine in cereal crops (Refs. 13, 20). 
 
Where possible, using wheat varieties low in asparagine, using wheat grown on sites that 
have shown reduced potential for asparagine accumulation in the past, and using wheat 
grown with adequate soil sulfate and without excessive nitrogen fertilization (Refs. 13, 20, 
30) may help reduce acrylamide formation in cereal products.  For the future, development 
of wheat varieties with low asparagine content under different growth conditions is a 
promising approach (Ref. 30). 
 
Summary: Using wheat varieties that are lower in asparagine and using wheat grown 
with adequate soil sulfate and without excessive nitrogen fertilization may help reduce 
acrylamide in cereal-based foods. 
 
Substitution.  Partial substitution of low-asparagine cereals for high-asparagine cereals (e.g., 
rice for wheat) may allow reductions in acrylamide, while still maintaining desirable product 
characteristics (Refs. 14, 17, 30, 31).  Reducing whole grain content may also reduce 
acrylamide (Refs. 20, 30-31), but FDA does not recommend this approach given the benefits 
of whole grains (Refs. 20, 105). 
 
Summary: Partially substituting low-asparagine cereal grains for high-asparagine 
cereal grains may help reduce acrylamide in cereal-based foods. 
Table 5: Summary for CEREAL-BASED FOODS: Raw materials 
 
  Using wheat varieties that are lower in asparagine and using wheat grown with 
adequate soil sulfate and without excessive nitrogen fertilization may help reduce 
acrylamide in cereal-based foods.  
  Partially substituting low-asparagine cereal grains for high-asparagine cereal 
grains may help reduce acrylamide in cereal-based foods. 
                                                           
14 Approximately 13.4 pounds/acre. 
 
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ii. Processing and ingredients 
This section provides information for different types of cereal-based foods, separated by 
type of processing intervention, rather than product category. 
Leavening.  The leavening agent ammonium bicarbonate increases acrylamide in baked 
goods containing reducing sugars by promoting the formation of reactive carbonyl sugar 
fragments (Ref. 106).  Replacement of ammonium bicarbonate in baked goods such as 
cookies and crackers with alternative leavening agents is a successful, industrially proven 
mitigation technique (Refs. 17, 30, 37-38, 44, 107).  According to the SFA, replacement of 
ammonium bicarbonate is one of the most effective mitigation techniques in cookies for 
smaller member companies, due to reasonable costs and limited impact on quality (Ref. 44).  
Alternative leavening agents include sodium bicarbonate and acidulants; sodium bicarbonate 
plus SAPP and organic acids; and potassium bicarbonate with potassium bitartrate (Refs. 17, 
31, 108-109). 
Proposals to substitute sodium bicarbonate for ammonium bicarbonate have raised concerns 
about the potential for increased sodium exposure (Refs. 20, 30, 31).  To minimize increases 
in sodium intake from using sodium bicarbonate, it is important to consider whether less 
sodium can be added elsewhere in the baking process, e.g., as an ingredient (Ref. 20).  Also, 
calcium and potassium-based leavening agents may be acceptable alternatives to sodium and 
ammonium-based leavening agents in some products (Ref. 108).  Compared with 
ammonium bicarbonate, alternative leavening agents may have unwanted effects on taste 
and texture, and cause decreased browning, more limited leavening, and slower gas 
generation in baked goods (Refs. 17, 20, 31, 110). However, quality effects may be very 
limited or acceptable (e.g., Ref. 107) and other changes may address some quality issues; 
e.g., adding organic acids to address alkaline taste or adding amino acids to increase 
browning (Ref. 106). 
Summary: Replacing ammonium bicarbonate in cookies and crackers with alternative 
leavening agents, while avoiding overall increases in sodium levels, may help reduce 
acrylamide. 
Sugars.  Replacement or avoidance of reducing sugars has proved to be a successful strategy 
for acrylamide mitigation in cookies, crackers, and other baked goods (Refs. 20, 30, 37-38).  
Replacement of reducing sugars with sucrose is particularly effective in sweet baked goods 
where browning is not critical (Ref. 31).  The following suggestions and comments apply to 
use of sugars in baked cereal-based foods: 
 Where possible, replace reducing sugars (e.g., glucose, fruit purees, inverted 
sugar, corn syrup, fructose, honey) with nonreducing sugars (e.g., sucrose or 
trehalose) (Refs. 13, 17, 20, 31, 106-107, 111-112). 
 For recipes that require reducing sugar, substitute glucose for fructose where 
possible.  For products using corn syrup, choose syrup with low fructose content 
(Refs. 30-31). 
 Replacement of reducing sugars (or replacement of fructose with glucose) may be 
most effective in products that contain ammonium bicarbonate (Refs. 20, 30, 106). 
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 Replacement of reducing sugars may cause a lighter colored product or interfere 
with flavor formation for some products (e.g., gingerbread), but not have a 
significant effect or unacceptable effect on other products (Refs. 20, 30, 38, 106). 
  For breakfast cereals, avoid adding reducing sugars (including fruit syrups and 
honey) to cereals before high-temperature cooking (toasting) steps (Refs. 30-31).  
Reducing sugars applied as coatings after cooking do not influence acrylamide 
levels (Refs. 30-31). 
 Decreasing molasses use in cookies may reduce acrylamide formation (Ref. 44). 
Summary:  Replacing reducing sugars with nonreducing sugars, using reducing sugars 
with lower fructose content, and only adding sugar coatings to breakfast cereals after 
toasting steps may help reduce acrylamide. 
Asparaginase.  Asparaginase treatment is one of the most effective practices adopted by 
manufacturers for cereal goods, with multiple products commercialized (Refs. 20, 30, 38, 
44).  Acrylamide reductions of approximately 35 to 90 percent have been reported for 
asparaginase treatment of various cereal-dough-based products in commercial or trial use, 
such as tortilla chips, corn chips, pretzels, crackers, crispbread, cakes, cookies (including 
gingerbread), honey cakes, and hydrolyzed ready-to-eat cereal products (Refs. 20, 30, 44, 
95, 111).  A major advantage of asparaginase is its limited effect on product characteristics 
or organoleptic properties, as might occur with recipe or process changes (Ref. 20). 
The primary factors affecting successful use of asparaginase in cereal-based products are 
enzyme dose, asparaginase-dough contact time, and dough water content (Refs. 30, 38, 44, 
95).  The enzyme can be added in a granular form to dry ingredients (e.g., in crackers or 
pretzels) or as a liquid (e.g., in tortilla chips and corn chips).  While some modifications to 
manufacturing lines may be necessary, e.g., to increase holding time in the presence of 
asparaginase, dry addition typically requires only minimal process changes (Refs. 20, 44, 
95).  Asparaginase effectiveness is greater in high moisture doughs compared with low 
moisture doughs (such as ginger cookies) (Refs. 30, 38, 95).  Also, asparaginase is not 
effective for breakfast cereals that have low moisture content or that are based on coarsely 
ground flours and chopped grains, because of limited penetration of asparaginase into the 
product (Ref. 30).  In addition, some ready-to-eat cereal production processes involve 
preconditioning that can deactivate asparaginase (Ref. 57).   
Chlorine content and pH also affect asparaginase activity.  Water containing chlorine or 
chlorine derivatives (e.g., public drinking water) may reduce asparaginase activity in cereal-
dough-based products (Ref. 44).  Laboratory testing of asparaginase revealed that an 
asparaginase enzyme (Novozymes, derived from A. oryzae) was most active at neutral pH, 
and that for most bakery products, asparaginase could be used at dough pH (Ref. 95). For 
masa15 preparation, the SFA reported that higher lime content could potentially raise dough 
pH and reduce asparaginase activity (Ref. 44). 
Summary: Using asparaginase treatment may help reduce acrylamide in cereal- based 
foods, but dose, contact time, dough water content, pH, and water chlorination are 
                                                           
15 Masa is a corn-based dough used to make tortillas and tortilla chips. 
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    Contains Nonbinding Recommendations 
important considerations. 
Treatment with cations.  For breads, fortification of flour16 with 0.3 to 1 percent calcium 
carbonate or calcium chloride reduced acrylamide levels compared with unfortified bread 
(Refs. 30, 110, 113).  Magnesium fortification at equivalent levels reduced acrylamide 
formation in bread to a lesser degree (Refs. 30, 110, 113).  Because acrylamide in bread 
forms primarily in crusts, applying calcium directly to dough surfaces, e.g., in releasing 
agents or on loaf tops, may be a useful approach (Refs. 30, 110).  Sodium chloride may also 
reduce acrylamide in breads, but Claus et al. (Ref. 114) reported that the optimal 
concentration of sodium chloride for acrylamide minimization is 1 to 2 percent and is 
routinely used in industrial bread production.  Calcium propionate should be avoided for 
acrylamide reduction as it caused a greater than 90 percent increase in acrylamide levels in 
bread (Ref. 30). 
For breakfast cereals, many cereals are already fortified with calcium.  Manufacturers may 
want to consider calcium addition for non-fortified cereals (Ref. 30).  Sodium chloride also 
may mitigate acrylamide in breakfast cereals (Ref. 115), but avoidance of excess dietary 
sodium also should be considered. 
For crackers (including crispbreads) and cookies (including gingerbread), calcium and 
magnesium supplementation showed potential to reduce acrylamide in laboratory trials 
(Refs. 110, 113), but product quality has been poor (Refs. 30, 110).  Also, in laboratory 
trials, calcium propionate (at 0.35 to 0.75 percent) accentuated acrylamide formation in 
cracker and cookie doughs (Ref. 110). 
Summary: Using calcium supplementation may help reduce acrylamide in non- 
calcium-fortified breads or breakfast cereals, but the addition of calcium propionate 
may increase acrylamide levels. 
Yeast fermentation.  Because yeast use asparagine during growth, some data indicate that 
yeast fermentation is associated with lower asparagine levels in doughs and lower 
acrylamide levels in baked cereal goods such as crispbreads (Refs. 17, 30, 111).  Longer 
fermentation time may be a useful strategy to reduce acrylamide formation in breads, 
crispbreads, and crackers (Refs. 12, 17, 30, 111), although extended fermentation also may 
have unwanted effects, such as weakened gluten and flatter breads (Ref. 12).  As an 
alternative to longer fermentation, greater quantities of low-gassing yeast can be used to 
increase asparagine consumption while keeping gas levels constant (Refs. 17, 30, 110).  A 
modified form of yeast that has increased rates of asparagine consumption has undergone 
the GRAS notification process in the U.S (Ref. 116).  It is important to keep in mind that 
recipe or process changes that affect yeast adversely (e.g., excess sodium chloride) also may 
affect final acrylamide levels (Refs. 12, 113).  
Summary: Using yeast fermentation and changing fermentation conditions may help 
reduce acrylamide in cereal-based foods. 
                                                           
16 In the U.S., enriched flour may contain 960 mg calcium/lb flour (21CFR137.165), or approximately 
0.2 percent calcium or 0.5 percent calcium carbonate. 
 
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Thermal input.  Modifications to baking time and temperature can result in lower acrylamide 
levels in baked goods, breakfast cereals, crispbreads, and other cereal-based foods (Refs. 20, 
30, 117). Products can be baked at lower temperatures for longer periods of time (Refs. 12, 
17, 30, 117-118).  Another approach is to lower baking temperatures during the final stages 
of cooking when moisture levels are low and acrylamide formation is more likely (Refs. 17, 
31, 113).  Likewise, it may be possible to increase temperatures earlier in the baking process 
when higher moisture levels should prevent acrylamide formation (Ref. 31).  Potential 
disadvantages of temperature reductions include slower production lines, lighter color (Refs. 
20, 30), shorter shelf life with higher moisture products, and the need for recipe changes 
(Refs. 17, 30).  For breads, convection ovens may give higher acrylamide levels than deck 
ovens, due to more intense drying of the crust (Ref. 12), while steam baking or baking with 
lidded pans reduced acrylamide levels compared with other baking techniques (Ref. 30).  
Alternative baking technologies, such as infrared radiation and air impingement, also can 
reduce acrylamide levels (Refs. 30, 111), but these technologies may not be in widespread 
use in the U.S. (Ref. 111). 
Summary: Lowering thermal input through modifying baking times and temperatures 
and considering alternative baking technologies may help reduce acrylamide in cereal-
based foods. 
Color.  For many cereal-based foods (e.g., breads), darker color can be a useful indicator of 
acrylamide levels, with a darker color being associated with higher acrylamide levels (Refs. 
17, 30); however, in a few products, such as some breakfast cereals, darker color may be 
associated with less acrylamide (Refs. 24-25).  Color may be a useful monitor of acrylamide 
levels during production or when investigating the effects of different baking conditions, but 
the correlation between color and acrylamide may have to be determined on a product by 
product basis. 
Summary: Monitoring production by using color as an indicator of acrylamide may 
help reduce acrylamide, but the correlation between color and acrylamide may have to 
be determined on a product by product basis. 
Moisture.  For some cereal-based foods (e.g., crispbreads), setting a higher finished moisture 
level may be a useful strategy for controlling acrylamide (Refs. 30, 37-38). However, too 
high a moisture level may impact product shelf life or flavor (Refs. 30, 44). Monitoring 
moisture levels in finished products may also be a good indicator of acrylamide levels in a 
product with standardized moisture levels (Ref. 30). 
Summary: Setting a higher moisture endpoint may help reduce acrylamide in cereal-
based foods, and monitoring moisture levels in finished products may be useful as an 
indirect indicator of acrylamide levels. 
24 
    Contains Nonbinding Recommendations 
Table 6: Summary for CEREAL-BASED FOODS: Processing and ingredients 
 
  Replacing ammonium bicarbonate in cookies and crackers with alternative 
leavening agents, while avoiding overall increases in sodium levels, may help 
reduce acrylamide.  
  Replacing reducing sugars with nonreducing sugars, using reducing sugars with 
lower fructose content, and only adding sugar coatings to breakfast cereals 
after toasting steps may help reduce acrylamide.  
  Using asparaginase treatment may help reduce acrylamide in cereal-based 
foods, but dose, contact time, dough water content, pH, and water chlorination 
are important considerations.  
  Using calcium supplementation may help reduce acrylamide in non-calcium-
fortified breads or breakfast cereals, but the addition of calcium propionate 
may increase acrylamide levels.  
  Using yeast fermentation and changing fermentation conditions may help reduce 
acrylamide in cereal-based foods.  
  Lowering thermal input through modifying baking times and temperatures and 
considering alternative baking technologies may help reduce acrylamide in 
cereal-based foods.  
  Monitoring production by using color as an indicator of acrylamide may help 
reduce acrylamide, but the correlation between color and acrylamide may have 
to be determined on a product by product basis.  
  Setting a higher moisture endpoint may help reduce acrylamide in cereal-based 
foods, and monitoring moisture levels in finished products may be useful as an 
indirect indicator of acrylamide levels. 
Other considerations  
The following section summarizes information on proposed acrylamide reduction 
techniques for cereal-based foods that have produced ambiguous results, and 
therefore may have not been successfully demonstrated on an industrial scale. 
Treatment with amino acids.  For breads, addition of various amino acids (e.g., cysteine, 
glycine) to doughs has been shown in laboratory and pilot plant trials to reduce 
acrylamide formation in various types of bread (Refs. 12, 30, 98, 114, 119).  However, 
excess cysteine in doughs can negatively affect bread structure and flavor.  Glycine also 
may mitigate acrylamide when added to bread dough or applied as a spray to the surface 
of the dough prior to baking (Refs. 12, 30, 110, 111, 119).  However, glycine in large 
amounts may reduce fermentation (Ref. 30).  Also, a glycine spray needed repeated 
applications and reduced acrylamide levels only about 15 percent (Ref. 30). 
25 
    Contains Nonbinding Recommendations 
 
For breakfast cereals, glycine reduced acrylamide formation (e.g., 50-75 percent) in 
wheat flake cereals in pilot trials, but also caused excessively dark colors and bitter taste 
(Refs. 17, 30).  Producing acceptable flakes required radical changes in the toasting 
operation (Ref. 17).  According to FoodDrinkEurope (Ref. 30), researchers have not 
been able to mitigate glycines effects on color and taste, while also meeting 
requirements for moisture, texture, and shelf life.  Added proline and lysine also caused 
unacceptably bitter flavors (Ref. 30). 
For cookies, crackers, and crispbreads, amino acids (e.g., glycine) were successful in 
reducing acrylamide levels in experimental trials (e.g., approximately 15 percent in 
savory biscuits to 80 percent in crispbread) (Refs. 30, 113), but poor product color and 
quality typically resulted (Ref. 30). 
Treatment with acidulants.  Acidulants such as citric acid reduce acrylamide levels in 
cereal dough-based products through their interference with the Maillard reaction17(Refs. 
8, 17, 30, 78, 110).  A manufacturer of citric acid products stated that it achieved 
acrylamide reductions of over 60 percent in breakfast cereals in industrial trials, from 30 
to 70 percent in cookies and crispbreads in laboratory trials, and up to 90 percent in 
gingerbread in industrial trials, without effects on taste (Ref. 78).  However, other sources 
report significant impacts in baked goods for acidulants, including sour taste, lessened 
browning, and a limited practical pH range for doughs (Refs. 17, 30, 113).  Another 
concern is that lowering dough pH may favor the formation of the undesirable chemical 
byproduct 3-monochloropropanediol (3-MCPD) (Refs. 17, 30, 110, 113).  Spraying 
dough surfaces with acidulants, rather than incorporating acidulants in dough, may avoid 
some side effects (Refs. 17, 78). 
Dough holding time.  Higher acrylamide formation was reported in aged (up to 3 hours) 
sweet cookie dough (Ref. 110), leading to recommendations to avoid letting doughs age 
(Refs. 30, 110).  However, a trade organization reported that this approach was not 
supported by further evidence (Ref. 38). 
Rework.  Initial research suggested that eliminating use of rework dough18 could lower 
acrylamide levels in certain baked goods (Ref. 30).  These results have not been born out 
in manufacturing settings (Refs. 30, 38).  More recent information suggests that in 
doughs with asparaginase, use of rework may reduce acrylamide by providing 
additional time for the enzyme to react (Ref. 57).  Manufacturers may wish to 
investigate individual products to determine if rework affects acrylamide levels.  
D. Other foods 
Coffee.  Coffee is a significant source of acrylamide exposure for adults.  Limited 
                                                           
17 The Maillard reaction is a non-enzymatic reaction between sugars and proteins that occurs upon heating 
and that produces browning of some foods.  See http://www.merriam- 
webster.com/dictionary/maillard%20reaction. 
18 For purposes of this guidance, the term rework dough refers to dough that is left over from preparing 
dough for manufacturing (such as trimmings left from cutting cookies on a baking sheet) and then is fed 
into the manufacturing process again. 
 
26 
  Contains Nonbinding Recommendations 
information is available on factors known to affect acrylamide concentrations in coffee. 
Robusta beans have somewhat higher acrylamide levels than arabica beans.  Dark roast 
coffee has less acrylamide than light roast coffee (since acrylamide formed early in 
roasting is destroyed later in the roasting process).  Acrylamide levels in roasted coffee 
decline during long-term storage.  Also, different preparation methods (e.g., espresso 
versus filter brewed) result in different levels of acrylamide in coffee as consumed (Refs. 
15, 30-31, 120). 
A number of mitigation methods have been suggested for coffee, such as steam roasting, 
vacuum roasting and asparaginase treatment (Refs. 15, 121-122), but FDA is not aware of 
any proven mitigation measures.  In more recent laboratory and pilot trials, treatment of 
green coffee beans with asparaginase resulted in lower acrylamide levels (5-45 percent) 
after roasting compared with untreated roasted beans, but coffee taste was significantly 
and negatively affected (Ref. 30).  A viable commercial process is not yet available (Ref. 
30). 
E. Preparation and cooking instructions on packaged frozen french fries 19 
For french fries, the recommended maximum cooking temperature for frying is 345-350 
oF/approximately 170-175 oC (Refs. 30, 43).  Providing appropriate cooking instructions 
on frozen french fry packages may help reduce acrylamide formation safely during final 
preparation by consumers and food service operators.  Examples of such instructions 
(which may not be applicable to all products) are: 
  Cook to a light golden color. Avoid browning fries. 
  Avoid overcooking or undercooking. 
  Avoid cooking in a toaster oven to prevent overcooking. 
  Reduce cooking time when cooking small amounts. 
Summary: Providing appropriate cooking instructions on frozen french fry 
packages to guide final preparation by consumers and food service operators may 
help reduce acrylamide. 
20
F. Information for food service operations  
Educating food service workers on the following techniques may help food service 
operations reduce acrylamide when frying potatoes, such as french fries: 
  Following manufacturer directions regarding frying oil temperature.  The 
recommended maximum oil temperature to avoid acrylamide formation is 345-
350 F (170-175 oC). 
  Cooking fries to a light yellow or golden yellow color. 
  If choosing to start with frozen product, cooking fries from the frozen state, not 
                                                           
19 This section draws on the following sources: Refs. 30-31, 41, 43. 
20 This section draws on the following sources: Refs. 30-31, 41, 43, 123.   
 
27 
    Contains Nonbinding Recommendations 
pre-thawing for quicker cooking.  Cooking frozen fries from the frozen state, as 
recommended by manufacturers, reduces increased oil absorption at lower 
cooking temperatures. 
  Screening out fines (very small pieces) after frying. 
  Avoiding overcrowding fryers, which can cause oil temperature drops followed by 
temperature surges.  High temperatures are more likely to produce acrylamide. 
  Removing fried products promptly from the fryer, or using automated fry removal 
equipment. 
  Calibrating fryers regularly to ensure that fryer temperatures are adequately 
controlled. 
  Changing older (overused) oil promptly.  Fries prepared in overused oils can 
appear darker than fries produced in fresh oil, making it difficult to check fry 
color. 
  Selecting fry varieties (e.g., potato variety, fry cut) that form less acrylamide 
when frying. 
Summary: Educating food service workers to follow proper frying techniques for 
french fries may help reduce acrylamide. 
The following techniques may help food service operations reduce acrylamide in foods 
made from fresh potatoes.  Some of these techniques are similar to those covered in 
Section B: 
  Selecting potato varieties for frying or roasting that produce lower levels of 
acrylamide, e.g., potatoes with lower reducing sugar levels.  Potential sources of 
information on acrylamide formation/reducing sugar levels include distributors, 
extension agencies, and trade associations.  Sweet potatoes can also form 
acrylamide. 
  Following proper procedures for handling fresh potatoes and requesting that 
suppliers do the same.  Proper handling is especially important for potatoes that 
will be fried or roasted.  Examples of such practices (from Section B) include not 
handling potatoes roughly, storing potatoes in a cool, dark place, and not 
refrigerating potatoes or storing them in freezing conditions. 
  Soaking raw potato slices in water for 15-30 minutes before frying or roasting to 
lower sugar levels before cooking, but drying pieces before frying. 
  Cutting thicker strips or larger pieces of potatoes when frying and roasting and 
removing very small pieces (fines) from fryers.  Smaller potato pieces are more 
likely to have higher acrylamide levels after frying. 
  Frying fresh-cut french fries or roasted potatoes to a light yellow or golden yellow 
color. 
Summary: Selecting potato varieties that are low in reducing sugars for frying or 
roasting, properly handling and storing potatoes, and using certain cooking 
practices for foods made from potatoes may help reduce acrylamide in potato-based 
foods. 
28 
  Contains Nonbinding Recommendations 
The following techniques may help food service operations reduce acrylamide in cereal- 
based foods: 
  Using color as an endpoint when preparing baked goods, such as baking and 
toasting breads and other baked goods to a light brown, not a dark brown color. 
In general, lighter-colored bread crusts and lighter-colored cookies will have 
lower acrylamide levels than darker versions of the same breads or cookies. 
  Overly dry or crusty cereal-based foods (such as baked goods) are also likely to 
have higher levels of acrylamide, so cooking to a moister endpoint may also help 
control acrylamide levels. 
Summary: Baking and toasting breads and other baked goods to a light brown, not 
a dark brown color; and avoiding overly dry or crusty products may help reduce 
acrylamide in cereal-based foods. 
Table 7: Summary for PACKAGED FROZEN FRENCH FRIES AND FOOD 
SERVICE OPERATIONS 
  Providing appropriate cooking instructions on frozen french fry packages to guide 
final preparation by consumers and food service operators may help reduce 
acrylamide. 
  Educating food service workers to follow proper frying techniques for french fries 
may help reduce acrylamide. 
  Selecting potato varieties that are low in reducing sugars for frying or roasting, 
properly handling and storing potatoes, and using certain cooking practices for foods 
made from potatoes may help reduce acrylamide in potato-based foods. 
  Baking and toasting breads and other baked goods to a light brown, not a dark brown 
color; and avoiding overly dry or crusty products may help reduce acrylamide in 
cereal-based foods. 
IV. References 
We have placed the following references on display in the Division of Dockets 
Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, 
MD 20852.  You may see them at that location between 9 a.m. and 4 p.m., Monday 
through Friday.  As of September 25, 2015, FDA had verified the Web site address for 
the references it makes available as hyperlinks from the Internet copy of this guidance, 
but FDA is not responsible for any subsequent changes to Non-FDA Web site 
references after September 25, 2015. 
 
Any references in this guidance to patents or patent applications are not intended to imply 
any manner of FDA support, favor, or endorsement. 
29 
    Contains Nonbinding Recommendations 
 
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31 
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    Contains Nonbinding Recommendations 
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