Undressing the Standards of Identity

Jan. 13, 2022

The FDA's new take on French dressing.

Apparently the United States no longer knows what French dressing is.

The FDA announced on Jan. 12 that French dressing will no longer be among the products for which it issues a “standard of identity.” As the Wall Street Journal explains, this action was in response to a request by the Association for Dressings and Sauces – a couple of decades ago.

If you’re reading this, you are probably familiar with the concept of FDA standards of identity, which extend to more than 270 different foods, from bread to frozen cherry pie. Briefly put, they set minimal standards for ingredients and composition. Some are very basic, like specifying that ketchup must be made only from tomatoes; others get specific, like the 10% minimum for milk fat in ice cream.

FDA standards of identity are sometimes used as a punchline, or punching bag, by politicians and pundits as examples of government overreach. And it’s easy to see how regulating French dressing falls into that category. As the Journal article points out, no such standards exist for, say, Russian or Thousand Island dressing. Why should French dressing be singled out? It’s especially absurd since French dressing, like French fries or French toast, is a food concept utterly alien to France.

The amount of time it took the FDA to resolve this is also bizarre. The Association for Sauces and Dressings filed its petition in 1998. Yes, the FDA has lots of higher priorities, but 22 years?

About a year and a half ago, the FDA announced plans to modernize the standards of identity. This action was supposed to be taken in 2005, but got delayed “due to resource constraints and competing priorities.”

The comment period for the regulation revisions terminated on July 20. If anything, the “competing priorities” are probably now more onerous than ever. But one hopes the FDA will, eventually, find the time to bring these regulations into the 21st century – especially since it missed its chance for the 20th.

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