Dear Commissioner Califf:
We are writing today with significant concerns about the harm being done to consumers and to maple sugar producers as the result of potentially false and misleading labeling of products that contain neither maple syrup nor real maple flavor. Specifically we call your attention to the attached letter signed by 12 maple producers' associations representing nine states and two countries, sent to Lynn M. Syzbist of the Food and Drug Administration (FDA) Office of Nutrition, Labeling and Dietary Supplements, dated February 9, 2016. We strongly support that request for the FDA to exercise its legal authority to investigate and take action against misbranded products in interstate commerce.
Maple syrup is a pure product, made 100 percent by concentrating the sap of maple trees. Pure maple syrup production (sugaring) provides income to an estimated 10,000 maple producers across 10 states in the Northeast and Upper Midwest, including Vermont, New York, Maine, Wisconsin, Pennsylvania, New Hampshire, Michigan, Ohio, Massachusetts, and Connecticut. The United States produced 3.4 million gallons of maple syrup in 2015, worth approximately $100 million dollars. For some, sugaring is full-time work, while others tap trees to supplement their income, providing an important source of earnings for many rural families.
The maple crop has high value because consumers seek out, and willingly pay a premium for, this pure, sustainably produced, natural product consisting 100 percent of the concentrated sap of maple trees. Consumers understand that maple syrup is produced from small, independent "sugar-bushes" that conserve hundreds of thousands of acres of mature hardwood forest across the Northeast, and support rural communities. Consumers are aware of the growing body of research showing nutritional benefits of pure maple syrup as compared to mass produced, manufactured sweeteners. What consumers don't know is that many of the products on store shelves labeled as "maple" and decorated with images of maple trees and North Woods settings often contain zero maple syrup.
The referenced letter of complaint provides compelling evidence of widespread intentional misrepresentation in the labeling of maple products. Product after product is cited that touts "maple" boldly on the front of the package, along with iconic images of maple sugaring, but show no maple at all on the ingredients list. These practices seem to intentionally mislead consumers who get cheap, industrially produced sweeteners and artificial flavors rather than the pure and genuine natural product they believe they have purchased. At the same time, sugar makers lose markets and income while the premium reputation of genuine maple syrup is damaged as consumers become used to inferior imitations.
We support a strong and thorough investigation into the misrepresentative labeling of food products whose labels incorrectly indicate the presence of maple syrup. We request appropriate enforcement action where warranted. The tradition of sugaring is significant not only to our cultural heritage, but to our efforts to strengthen the working landscape and local agriculture in our states.
Thank you for your consideration of this important and timely request. If we can provide further evidence of our concern with this troubling practice, please do not hesitate to contact us.