Dietary Guidelines

Letter to HHS: Concerns Regarding ICCPUD Alcohol Intake & Health Report 

Today the Consumer Choice Center submitted a formal comment to the Department of Health and Human Services to express our sincere concern about bias in the Interagency Coordinating Committee on the Prevention of Underage Drinking (ICCPUD) Alcohol Intake and Health (AIH) report, which could impact the 2025-20230 US Dietary Guidelines. Consumers need the best available information and clearly communicated, in-context summation of risks associated with alcohol, and the ICCPUD failed to do this, as CCC has previously made known.

HHS-CCC-Kent-Response (1)Download

OR MEDIA QUESTIONS OR INTERVIEWS CONTACT:

Stephen Kent

Media Director, Consumer Choice Center

stephen@consumerchoicecenter.org

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The Consumer Choice Center is an independent, nonpartisan consumer advocacy group championing the benefits of freedom of choice, innovation, and abundance in everyday life for consumers in over 100 countries. We closely monitor regulatory trends in Washington, Brussels, Ottawa, Brasilia, London, and Geneva. Find out more at www.consumerchoicecenter.org

FDA’s Ban on Red Dye No.3 Defies Scientific Evidence

Today the FDA issued a highly anticipated ban on Red Dye No. 3 as a color additive for food and ingested drugs. In their public statement, the FDA says in the same span of 295 words that Red No. 3 is being banned for representing a threat to public health, while also saying “there is no evidence showing FD&C Red No. 3 causes cancer in humans.“

Stephen Kent, an analyst for the Consumer Choice Center (CCC), an international consumer advocacy group, said of the FDA action:

“These color additives are in food and medicines for a reason, and it’s because consumers by-in-large enjoy the products more when they’re aesthetically pleasing. The campaign against Red No. 3 has been a scientific empty vessel from the start. Proponents of this ban will say that it’s not a big deal to have cereal, frozen treats and cupcakes be less colorful when public health is at stake, but they’ve failed to show evidence of harm and have instead relied on misinformation campaigns by social media influencers to frighten the public,” said Stephe Kent.

The FDA is relying on enforcing the Delaney Clause, enacted in 1960 as part of the Color Additives Amendment to the FD&C Act, which prohibits FDA authorization of a food additive or color additive if it has been found to induce cancer in humans or animals.

The ban takes effect in January 2027, offering further evidence of the lack of emergency or public health impact of these common additives on consumers. 

Kent continued, “You could argue the FDA is simply enforcing the law as it is written. When rats were exposed to the dye at extraordinarily high levels, cancer was a result – but it simply isn’t the case in human beings, and they know it. So the law needs to be changed and the public needs better information about the known risks. Red Dye No. 3 isn’t harmful, so we’re just going to have less visually appealing goods because of a law from 1960.” 

Read more about the Red No. 3 debate from the CCC

Washington Examiner

Newsmax Online

Bill Wirtz of the Consumer Choice Center told Newsmax prior to the FDA ban, “Here’s the crucial point to consider: The word “linked” does a lot of heavy lifting here because this particular dye only affected rats that were given unusually high doses in scientific studies. One could write at length about the reliability of animal studies and what they really mean for humans, but the mere fact that the doses were much higher than what even a human would consume shows us that environmental activists do not understand the concept of dosage. Too much of anything will be bad for you — in fact, “too much” describes quite literally the exact quantity that is excessive. For instance, this is equally true for glyphosate residues in beer or aspartame sweetener in Diet Coke. You would need to drink 264 gallons of beer for the glyphosate to adversely affect you or gulp down 36 cans of sugar-free Coke for the aspartame to be bad for you.”

OR MEDIA QUESTIONS OR INTERVIEWS CONTACT:

Stephen Kent

Media Director, Consumer Choice Center

stephen@consumerchoicecenter.org

###

The Consumer Choice Center is an independent, nonpartisan consumer advocacy group championing the benefits of freedom of choice, innovation, and abundance in everyday life for consumers in over 100 countries. We closely monitor regulatory trends in Washington, Brussels, Ottawa, Brasilia, London, and Geneva. Find out more at www.consumerchoicecenter.org

ICCPUD Report on Alcohol Deserves Skepticism

After months of controversy around its development, Health and Human Services (HHS) has published its highly anticipated report on alcohol and health through the Interagency Coordinating Committee on the Prevention of Underage Drinking (ICCPUD). The research was slammed in an October letter from 100 US Congressmen who expressed concern over its lack of transparency and known conflicts of interest by researchers involved in the ICCPUD report. 

The Consumer Choice Center’s (CCC) David Clement offered skepticism about the ICCPUD findings, saying “This research was way off target from the ICCPUD’s purpose, which is preventing underage drinking, and has instead focused on promoting abstaining from alcohol across all age groups. You don’t have to dig deep to find the ICCPUD report is co-authored by Tim Naimi, an anti-alcohol activist researcher with declared financial ties to the International Order of Good Templars, also known as Movendi, a temperance group.”

<< Read the CCC in the Washington Examiner on ICCPUD report >>

The ICCPUD report directly conflicts with another government-funded study on alcohol that was published in December by the National Academies of Sciences, Engineering, and Medicine (NASEM), which had a Congressional mandate for their research on alcohol. It found that moderate drinking is associated with a lower risk of cardiovascular disease compared to no alcohol consumption, and a lower risk of “all-cause mortality”. Heavy drinking increases those risks.

Clement continued, “This wave of conflicting information is a problem for consumers because the federal government’s consistent messaging on responsible drinking has made a real positive difference in curbing abuse. A prohibition mindset always backfires by misconstruing risk calculations to the public”

<< Read David Clement in the Financial Post on alcohol studies >>

There has been a steady stream of breaking news on alcohol and consumer health in recent weeks, peaking with the US Surgeon General’s advisory on a “causal link” between alcohol consumption and the risk of contracting cancer. The Consumer Choice Center has also expressed concern over that report and its stretched definition of what constitutes a meaningful “risk” to the consumer. 

“It is no small thing that 100 members of Congress asked for this ICCPUD research to be suspended before the new year. It hasn’t been transparent and did not allow for the proper vetting of researchers. And now we know why,” said David Clement. Experts from the International Scientific Forum on Alcohol Research (ISFAR) have called the work of authors behind the ICCPUD “pseudo-scientific”. “

“With the 2025-2030 Dietary Guidelines coming together, Americans rely on unbiased government guidance for food and beverages like alcohol, and this ICCPUD report is highly counterproductive,” concluded Clement. 

OR MEDIA QUESTIONS OR INTERVIEWS CONTACT:

Stephen Kent

Media Director, Consumer Choice Center

stephen@consumerchoicecenter.org

###

The Consumer Choice Center is an independent, nonpartisan consumer advocacy group championing the benefits of freedom of choice, innovation, and abundance in everyday life for consumers in over 100 countries. We closely monitor regulatory trends in Washington, Brussels, Ottawa, Brasilia, London, and Geneva. Find out more at www.consumerchoicecenter.org

NASEM Findings On Alcohol Safety Are A Win For Science & Consumer Choice

After Congress allocated $1.3 million to the Department of Agriculture and the National Academies of Sciences, Engineering, and Medicine (NASEM) to study alcohol’s impact on consumer health, the findings have been released in time to inform the 2025-2030 U.S. Dietary Guidelines. NASEM’s findings were published today in the Review of Evidence on Alcohol and Health and reported on by POLITICO.

Stephen Kent of the Consumer Choice Center praised the National Academies’ process to research on alcohol, saying,

“There has been intense downward pressure by anti-alcohol activists within the World Health Organization to steer government recommendations against any and all consumption of alcohol, even at responsible levels. Consumers rely on unbiased government research to inform their dietary choices and NASEM delivered on their Congressionally backed mandate to review alcohol’s impact on individual health.”

The Biden Administration’s Health and Human Services (HHS) also launched its own health study on alcohol, not sanctioned by Congress, through the Interagency Coordinating Committee on the Prevention of Underage Drinking. Consumer advocates and 100 Congressmen expressed concern that the HHS report lacked basic transparency and independence from activists seeking to discourage Americans from drinking alcohol. 

** READ MORE FROM STEPHEN KENT: End HHS’ Misadventure on Alcohol Research (WASHINGTON EXAMINER) **

Kent continued, “The appearance of outside influence by the international temperance group, Movendi, is not an insignificant concern with how HHS has approached their research. Imagine a set of federal dietary guidelines featuring input from PETA regarding meat consumption. NASEM had a sufficiently transparent process that involved Congress and should be the only report considered by the USDA as they finalize the next set of US Dietary Guidelines.”

Takeaways from the National Academies report include: 

  • Moderate drinking is associated with a lower risk of cardiovascular disease compared to no alcohol consumption.
  • Moderate drinking is also associated with a lower risk of “all-cause mortality”, though heavy drinking increases such risks.
  • The existing recommendations of limiting drinking to 2 drinks a day for men and 1 for women are reasonable and safe guidelines for consumer enjoyment of alcohol. 

OR MEDIA QUESTIONS OR INTERVIEWS CONTACT:

Stephen Kent

Media Director, Consumer Choice Center

stephen@consumerchoicecenter.org

###

The Consumer Choice Center is an independent, nonpartisan consumer advocacy group championing the benefits of freedom of choice, innovation, and abundance in everyday life for consumers in over 100 countries. We closely monitor regulatory trends in Washington, Brussels, Ottawa, Brasilia, London, and Geneva. Find out more at www.consumerchoicecenter.org

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