Regulatory Nonsense: Frozen Lemonade Concentrate

FDA recently announced that it may delete some outdated food standards — these are legally mandated recipes that FDA created to “promote honesty and fair dealing in the interest of consumers.” On FDA’s list is frozen cherry pie and I’d like to propose another one from the frozen food isle: frozen lemonade concentrate.

That’s correct, FDA has a food standard for frozen lemonade concentration, three actually:

  1. using a nutritive carbohydrate sweetener,
  2. using an artificial sweetener, and
  3. adding color (like to make pink lemonade).

Lemonade Concentrate, PictsweetFrozen lemonade concentrate is a simple thing: (1) lemon juice and juice concentration, and (2) sweetener (nutritive or artificial). The colored version includes some colorant to make it pink. Beyond the ingredients, the standard establishes the amount of lemon juice, acidity, and its sweetness. The product is then mixed with water to make a refreshing lemonade.

Right next to the frozen lemonade concentrate is frozen limeade concentrate. Alas there is no food standard for that product. Perhaps more surprising, there is no food standard for lemonade — regular, non-concentrate, non-frozen lemonade. In fact, FDA never established a food standard for regular lemonade — they wrote one, then promptly stayed it, and then deleted it 14 years later.

With no food standard, regular lemonade has innovated and offers the consumer several varieties to fit their personal preferences and price point.

  1. Product that is similar to the frozen concentrate: greater than 11% lemon juice and about 28 grams of sugars per serving.
  2. Product that has lemon juice and is equally sweet, but also blended with other fruit juices, like raspberry or strawberry.
  3. Product that is 3% lemon juice that is equally sweetened.
  4. Product that has no lemon juice but is equally sweetened.
  5. Product that is approximately ⅔ the amount of lemon juice and sweetener.
  6. Product that is powder consisting of lemon juice and oil, but also sweetened with stevia as well as sugar.

Except perhaps for the fountain drink with no lemon juice, it is hard to imagine that the consumer is confused or has not been subject to fair dealing. They know the quantity of juice in the product through the percent juice declaration and they know the sweetness of the product through the nutrition facts panel and how the beverage is sweetened through the ingredient list. So having a food standard for lemonade seems a bit unnecessary and, after 61 years, may it is time to retire the frozen concentrate lemonade food standard.

Frozen Lemoade Ad
This innovation for lemonade came into being in the early 1950s and allowed folks to enjoy inexpensive lemonade all year round.

Look here for more vintage lemonade concentrate ads.

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