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The Honorable Thomas 1. VilsackSecretary of AgricultureUnited States Department ofAgriculture1400 Independence Avenue, SWWhitten BufldlDs. Room 200AWashington. DC 20250The Honorable Jon LeibowitzChaIrmanFederal Trade Commission600 Pennsylvania Avenue, NWWashington, DC 20S80

WASHINGTON.I;)C10S10July 15,2011

The Honorable Margaret A. HamburgCommissionerFood Bft4Drua Admiuistratie>n10903 New Hampshire AvenueBuilding ), R.i3om 2217SllvCf Spring, MD 20993The Honorable Thomas R. F r l e d e u ~ MD, MPHDirectore.rs for Disease Control and Pre:vcmtion1600 CliftonR.oadAtlanta, OA 30329-4018

Dear Secretaty Vilsack, Chabman Leibowitz,. Commissioner HambufSI and Director Frieden:We understand that an Interagenc1 Worldng Group (lWG) compriseQ ofth. U.S. Department ofAgriculture, Federal Trade Conunission. U.S. Food and Drug AdmiDistrationl and the Centers forDisease Control mdPrevention recently relessed proposed gIlideHnes for food and beverage marketingto childrrm IUld teens. Tho guideliaos. ''Preliminary Proposed Nutrition Principles to Guide IndustlySelfwR.egulatoXy Efforts,II would requJ:e all food marketed to children and toens meet two nutritionprinciples: one. that foods contribute 8l1isnincIDt amount of certain foods StOUps (e.g. hits, vegetable&,whole grains, em); and two, that foods have very low amounts of eatunl1ed fat, trans fat. added sugaI'II,and sodium.We certainly agree that childhoDd obesity is a challenge deserling our attention. However. afterreviewing the proposed prinoiples, wo have a few questiona regerdlna the impacts that thesegwdeImes-iffullyadopted-will have on the U.S. economy and the U.S. food 8Jld agricultural

industries. Please provide for us the data to answer the questions below.Oiven that the 2005 Institute ofMedicine report. "Food Markeringto Children and Youth! Threator Opportunity?", found there was not sufficient evidence to find a causal relationship betweenadvertising and obesity, what data did the IWG use to demonstrate a linlc between advertisingad obesity?What data was used to SUP,POl't recommendations that are different than the science-basednutritional :ecommendations utilized. in the Fcdcral acho.o! Meals Programs and other nutritionassistance ,Ptoarams for children? Further. what data was used to support recommendations thatare different than the requirements estabU,hed by USDA and FDA to designate products as"Low Pat" or "Healthy?"What impact will these guideHnes have on the consumptiOJ1 of various foods end food smuJ'S(e.g- cereal, wheat bread, oatmeal, rice, beef: poultry. pork products. fluid milk t yogurt. cheesefnuts, legumes. fruits. and vegetables)? \Vbat economic impact win these principles have on U.S.

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Lettcrto Secretaty Vilsack. ChairmanLeibowitz. Cormnissioner Hamburg, and Director FriedenJuly IS, 2011Page 2 producers and p r o ~ e s s o r s of these products? What implications did the agencies determine with.regard to jobs 1n these impacted areas?Given the broad definition of'lnarketint' in the proposal, W8 understand that businesses may belimited from providing support 10 school aod communitr philantbropio activities; includingsports teams. literaoy progmms, and other hea.lthhptomotinl youth activities. What analysis wasdone regarding the eoonomic impaotto schools and oommunitie8?It is important lbat we consider and understand the Impact that tbia proposal win have on thevarious sectors of the U.S. economy as well as COZWlmers and young people. Thus. we look forward toreceiving the IWO's ;respOnse to these imporhlnt questions. In the interim, we uk "that you withhold any1Urther action, except for the process ofanalyzing comments to theproposal.

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Sincerely,

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cc: norable Kathleen Sebelius,of1he DepartmentofHealth and Human Services

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