IN A NUTSHELL
There are no regulations that require the identification (labeling) of all processed free glutamic acid (MSG) present in processed food. Consumers have no way of knowing if there is processed free glutamic acid (MSG) in processed food, and if there is any, how much or how little there is.
The FDA has proposed no regulations for identifying all processed free glutamic acid (MSG) in processed food.
Never has the FDA suggested that all MSG in processed food might be labeled.
Similarly, consumers have no way of knowing how much processed free glutamic acid (MSG) remains in and/or on MSG-sprayed crops (produce) when brought to market.
When consumers use the term "MSG," they are talking about a substance that causes adverse reactions ranging from skin rash and itching to hives, nausea and vomiting, migraine headache, asthma, heart irregularities, seizures, and depression. To cause an MSG-reaction, the glutamic acid in an ingredient must be free (not bound) glutamic acid, and the free glutamic acid must occur as a consequence of processing (manufacture) or fermentation.
The glutamic acid found in unadulterated, unprocessed, unfermented food is L-glutamic acid, only. With possible rare exception, that L-glutamic acid is bound up in protein with other amino acids i.e., tied to other amino acids like beads are tied in a necklace. It is tied to other amino acids. It is not processed (manufactured) free glutamic acid. It does not cause adverse reactions.
A food that has not been fermented, adulterated, manufactured, or otherwise processed, will not typically cause adverse reactions. If there were some minute amount of free glutamic acid in a fresh picked unspoiled (not over ripe) tomato, for example, that unprocessed free glutamic acid would not cause adverse reactions.
EXISTING FOOD LABELING REGULATIONS LEAVE CONSUMERS VULNERABLE TO HIDDEN MSG
Consumers have no way of knowing how much, or how little, processed free glutamic acid (MSG) there is in any processed food. Most food labeling regulations call for ingredient labeling, i.e, identifying ingredients by what the FDA calls their "common or usual names." Corn, salt, rye, autolyzed yeast, hydrolyzed soy protein, chicken, enzymes, and monosodium glutamate are examples of names of ingredients. But processed free glutamic acid (MSG), like fat and cholesterol, is usually a component or constituent of an ingredient, not an ingredient. So although the amount of processed free glutamic acid (MSG) could be listed on food labels just like fat and cholesterol are listed, there are no regulations requiring that the amount of processed free glutamic acid (MSG) in processed food be given.
FDA regulations require that ingredients be listed on labels by what the FDA calls "common or usual names." Common or usual names of ingredients that often or always contain processed free glutamic acid (MSG) include "autolyzed yeast extract," "sodium caseinate," "maltodextrin," "hydrolyzed lecithin," "monosodium glutamate," and "natural flavoring." But "monosodium glutamate" is the only ingredient name that gives even a clue to the fact that the ingredient contains processed free glutamic acid (MSG). There are no regulations that require manufacturers to mention constituents of ingredients, like "free glutamic acid," on labels of processed food.
Many food ingredients contain processed free glutamic acid (MSG). "Glutamic acid" is the common or usual name given to 100 per cent pure free glutamic acid. "Monosodium glutamate" is the common or usual name given to a combination of processed free glutamic acid (MSG), sodium (salt), moisture, and not more than 1% impurities. "Autolyzed yeast," "calcium caseinate," "yeast food," "yeast extract," and "hydrolyzed soy protein," are examples of names of ingredients that contain lesser percentages of processed free glutamic acid (MSG) than monosodium glutamate contains.
Some food ingredients, enzymes and malted barley for example, do not contain processed free glutamic acid (MSG), but create processed free glutamic acid (MSG) when they are combined with protein during processing.
One might argue that consumers could learn the names of the seemingly infinite number of MSG-containing ingredients on the market at any given time. But even that wouldn't protect consumers from hidden processed free glutamic acid (MSG), because current FDA regulations allow that certain products such as "stock" and "broth" can be used as ingredients in products without listing/naming the ingredients contained in the "stock" or "broth." Thus, "stock" or "broth" that contain "hydrolyzed soy protein," "autolyzed yeast," and "sodium caseinate," for example, could be used in "mushroom soup" and labeled "stock" or "broth" without mentioning the three sources of processed free glutamic acid (MSG): "hydrolyzed soy protein," "autolyzed yeast," and "sodium caseinate."
Current FDA regulations also allow certain MSG-containing ingredients to be included under the label descriptors "flavor(s)", "flavoring(s)", "natural flavor(s)", and "natural flavoring(s)" without disclosure of the processed free glutamic acid (MSG) in them, or even mention of the ingredients' names. In recent years, the FDA issued a regulation requiring that when used in the proprietary ingredients flavor(s)", "flavoring(s)", "natural flavor(s)", or "natural flavoring(s)", the ingredients “monosodium glutamate” and “hydrolyzed…protein” had to be disclosed. That leaves autolyzed yeast, sodium caseinate, maltodextrin, citric acid, and more than 40 other MSG-containing ingredients to be used in these proprietary products without disclosure. And given the fact that the FDA makes no attempt to enforce its regulations pertaining to use of “monosodium glutamate” and “hydrolyzed…protein”, these proprietary ingredients may contain “monosodium glutamate” and “hydrolyzed…protein”, also.
Finally, processed free glutamic acid (MSG) can be produced during processing. For example, certain enzymes combined with protein will create processed free glutamic acid (MSG) during product processing. Under present FDA regulations, "enzymes" would be listed as ingredients with no indication that during processing enzymes would create processed free glutamic acid (MSG). Certain processes, such as ultrapasteurization, can similarly free glutamic acid from the milk protein that contains it, and thereby produce processed free glutamic acid (MSG).
There's more. In 1998, the EPA approved the use of processed free glutamic acid (MSG) in sprays to be used on fruits, grains, vegetables, and other vegetation. Consumers have no way of knowing what produce has been sprayed with MSG-containing plant "growth enhancers," how much MSG-residual remains on the plants, or how much MSG has been absorbed into them.
THE FDA, EPA, AND USDA WORK HAND IN HAND WITH INDUSTRY TO CREATE CONSUMER CONFUSION
The FDA has acknowledged that "...consumers frequently use the term MSG to mean all free glutamate"(2). But the FDA insists on using, and, thereby, encouraging manufacturers to use the term "MSG" as an abbreviation for the ingredient called "monosodium glutamate." This is a source of tremendous confusion. It also helps the glutamate industry hide processed free glutamic acid (MSG) in processed food. When a consumer calls a manufacturer to ask if a certain product contains "MSG," the consumer might think he/she is asking about all processed free glutamic acid (MSG) that causes migraine headache, pounding heart, or other problems; but manufacturers often respond by telling consumers only whether or not their products contain an ingredient called "monosodium glutamate," referring to "monosodium glutamate" as "MSG." So, if you want to know whether or not there is processed free glutamic acid (MSG) in a product, ask about "free glutamic acid." Do not ask about "MSG." That won't necessarily get you an honest answer to your question, but it will give you the best chance of getting one.
A second source of confusion lies in the fact that the FDA allows industry to identify ingredients as “natural” or “naturally occurring” without regard for the chemical composition of those products or the degree of processing to which they have been subjected.
EXISTING REGULATIONS DO NOT PROHIBIT THE LABELING OF MSG
There is no law or regulation that would prevent the FDA from requiring that the amount of processed free glutamic acid (MSG) in every ingredient and/or product must be identified on the labels of processed food. The FDA requires that sulfites must be identified on product labels when they exceed 10 parts per million, regardless of whether sulfites are an ingredient in and of themselves, or are a component or constituent of an ingredient. The FDA also requires that the amounts of saturated fat, cholesterol, and sodium, for example, must be listed on the labels of processed food.
Indeed, there is no law or regulation that would prevent the FDA from restricting the use of processed free glutamic acid (MSG). According to Hugh C. Cannon, former FDA Associate Commissioner for Legislative Affairs, "...use of such substances can be restricted if evidence warrants the conclusion that they are not safe under their conditions of use."
PROPOSED REGULATIONS ARE A FICTION. THE LAST FDA PRETENSE AT CONSIDERING LABELING WAS WITHDRAWN WHEN THE LAWSUIT THAT WOULD HAVE REQUIRED MSG TO BE IDENTIFIED ON LABELS OF PROCESSED FOOD WAS DISMISSED AT THE REQUEST OF THE FDA.
The Truth in Labeling Campaign has proposed that all MSG in all processed food be labeled -- that the amount of MSG in the end product of every processed food be identified and noted on the product's label - that the amount of MSG be given in milligrams.
The FDA has talked of proposing regulations for identifying processed free glutamic acid that occurs in food as a consequence of manufacture (MSG) since 1990, if not before. However, at this time, there is not even a proposed regulation that addresses the labeling of all MSG in all processed food.
On January 6, 1993, regulations pertaining to the labeling of some MSG, but not all MSG, were proposed in the Federal Register. Because the proposed regulation would not identify MSG whenever and wherever it occurred in food, the regulation, if passed, would have had no positive value. In fact, by claiming that MSG was labeled when it was not always labeled, implementation of such a regulation would actually cause confusion.
On August 31, 1995, following release of the FDA sponsored report on the safety of MSG, done for the FDA by the Federation of American Societies for Experimental Biology (FASEB), FDA Commissioner David A. Kessler, M.D. announced that, with limited exception, MSG had been reaffirmed "safe." Dr. Kessler went on to say that the FDA will consider labeling "significant" amounts of MSG, and that a new regulation to label "significant" amounts of MSG would soon be proposed in place of the 1993 proposed regulation to label "some" MSG. That was August 31, 1995.
How, then, did the FDA justify its claim that they were considering labeling MSG? First and foremost, note that the FDA made that claim only to consumers, to the Court (when consumers appealed to the Court to intercede on their behalf), and to legislators who inquire about labeling on behalf of consumers. To the industry, the FDA has always asserted that there will be no labeling of MSG.
Apparently prompted by a law suit filed in Federal Court on August 29, 1995, the FDA initiated an action that would keep processed free glutamic acid that occurs in food as a consequence of manufacture (MSG) hidden in food while pretending to protect consumers from inadvertently ingesting levels of MSG that could cause adverse reactions. Their vehicle was a two part, nine page Advance Notice of Proposed Rulemaking (ANPR) published September 12, 1996 in the Federal Register (pages 48102-48110). In the ANPR, the FDA called for comments on whether the FDA should establish labeling requirements to alert MSG-intolerant consumers to the presence of free glutamate in food, and whether the agency should establish formal criteria for the use of claims about the absence of MSG.
The ANPR itself bears witness to the FDA's lack of good faith as it pretends to be concerned that the needs of MSG-sensitive consumers should be addressed. It is full of half-truths and misinformation as well as literally false statements. In addition, it failed to include a great deal of information relevant to any consideration of the toxicity of MSG. That such a document should have been published is a disservice to the American people and a disgrace to this nation.
Labeling recommendations put forth by the FDA in the ANPR rested on the out and out lie spawned by the glutamate industry and the FDA that the scientific literature clearly demonstrates that MSG-reactions do not occur following ingestion of less than 3 grams of MSG. In stark contrast to the industry/FDA unconscionable fabrication are the facts that:
1) There are, in the scientific literature, a number of studies wherein adverse reactions to less than 3 grams of MSG were documented, and
2) No study to determine the least amount of MSG that would cause an adverse reaction in an MSG-sensitive person has ever been done.
Given that the label of Accent brand monosodium glutamate says that one serving of pure monosodium glutamate is .5 grams of monosodium glutamate (of which approximately .39 grams might be MSG); and that 6 ounce servings of canned soups, which are common MSG-reaction triggers, each generally contain approximately .6 grams of MSG, it becomes immediately obvious that by using 3 grams as a basis for labeling, most MSG would remain hidden, and labeling some MSG but not all MSG would cause more confusion than benefit to consumers.
In Proposal 2 of the ANPR, the FDA recommended that the regulations then (and now) on the books (although not enforced) prohibiting manufacturers from claiming "no MSG" on labels of foods that contain any form of MSG be changed. Easy, you say? Surely, cracking down on offenders and manufacturers will stop this illegal labeling practice. Easy, says the FDA. Change the regulations to make it legal for a product with as much as .2 grams of MSG per serving in it to claim that the product contains no MSG.
Please note that the ANPR was not a proposed rule. It was an announcement asking for comments on whether there should be a proposed rule. Because the Docket (96N-0244) was not closed, input to the ANPR was not evaluated. With the Court's decision to defer to the FDA on the matter of labeling MSG, the FDA dropped much of its pretense of considering labeling. Federal regulations require that subjects being considered by the FDA be dispatched in a timely fashion. But the clock does not begin to run until the docket is closed. As of February, 2003, the FDA had not closed the ANPR docket. According to conversation with Dockets Management on January 5, 2009, the ANPR was withdrawn in 2004 – without being evaluated.
USE OF "NO MSG," "NO ADDED MSG," AND "NO MSG ADDED," ON LABELS OF PROCESSED FOOD THAT CONTAINS PROCESSED FREE GLUTAMIC ACID (MSG) IS ILLEGAL -- BUT UNREGULATED
Existing regulations prohibit the use of the words "NO MSG," "NO ADDED MSG," and "NO MSG ADDED," on labels of processed food that contains processed free glutamic acid (MSG). But by and large, the FDA does not enforce those regulations, and the US Department of Agriculture actually approves labels that violate the regulations.
If you have interest in reviewing the ANPR or any other material submitted to the Docket, you can contact Dockets Management:
Dockets Management Branch
Food and Drug Administration
5630 Fishers Lane
Rockville, MD 20852
(They no longer take email.)
1. Leung, A. and Foster, S.(1996). Encyclopedia of Common Natural Ingredients Used in Food, Drugs, and Cosmetics. New York: Wiley.
2. FDA Backgrounder, August 31, 1995.