Your email notes that we have lobbied against the Interagency Working Group (IWG) proposal. That is correct. We have serious concerns about the IWG proposal.

Our most advertised product is cereal – and we stand behind it. Cereal is one of the healthiest breakfast choices you can make… If it is a General Mills cereal, it will also be a good or excellent source of whole grains.

Childhood obesity is a serious issue – and General Mills wants to be part of the solution. But if the issue is obesity, cereal should perhaps be advertised more, not less.

…You can be assured than food and beverage companies have studied every letter, comma and period in the proposal. We know what it says, and what it does not.

For example, we know that 88 of the 100 most commonly consumed foods and beverages could not be marketed under the IWG guidelines. The list of “banned” items under the guidelines would include essentially all cereals, salads, whole wheat bread, yogurt, canned vegetables, and a host of other items universally recognized as healthy [Note: I’m not at all sure this is true–MN].

Despite the characterizations used to advance them, the IWG guidelines would not be voluntary, in our view. The IWG guidelines are advanced by two of the agencies most responsible for regulating the food industry, as well as the agency most responsible for regulating advertising. Ignoring their “voluntary guidance” would not be an option for most companies.

Regulation has already been threatened (even demanded) should companies choose not to comply – and litigation would inevitably follow.

The IWG guidelines also conflict with most existing government programs and definitions relative to food. For example, many products that meet the U.S. Food and Drug Administration’s current definition of “healthy” could not be advertised under the IWG guidelines [It would be interesting to see examples].

Many products included in the U.S. Department of Agriculture’s Supplemental Nutrition Assistance Program fail the IWG standards, as do most products encouraged and subsidized under the USDA’s Women, Infants and Children Feeding Program (WIC) [If so, this is a sad commentary on what we encourage low-income mothers and children to eat].

Finally, your email suggests companies should focus on providing feedback via public comment. We agree. We have reviewed every detail of the IWG proposal – and we remain opposed, as our public comment explains.