Thank you very much for this document and for giving experts the opportunity to comment on it.
I have some comments on one single point: in section 3.1 on food systems, the document endorses WHO recommendations for an "intake of free sugars less than 10% of total energy intake, or, preferably, less than 5%". This is a draft recommendation, still under discussion. Recently, similar draft recommendations were released for discussion in the UK as well. There are however an number of important issues to consider regarding dietary sugars, ie:
- there is no current scientific evidence supporting adverse effects of sugars at a threshold of 5% (or 10%) total energy. These recommendations are therefore extremely cautious on sugars.
- expressing sugar intake as % total energy may be misleading, unless one specifies "energy intake corresponding to that needed to maintain a normal body weight"
- while its is amply justify to recommend energy and sugar reduction in overweight subjects as a way of reducing body weight, recommendations to decrease total sugar intake (from 10-15% presently to 5%) at the general population level should be assorted of specific recommendations on how to replace sugar energy. One can fear that replacing sugar calories with refined cereals or saturated fat may have undesirable effects on health!
- Given the fact that sugar from fruits is metabolized the same way as added sugar, the definition of free "unhealthy" vs "natural,healthy" sugars is tricky. This is an important issue to avoid confusion and to ensure proper labeling of industry products.
These are important points which remain presently unsettled and will have to be very carefully addressed in the final document.
Luc TAPPY, M.D.