Madam,

We read with interest the research article by Wilde et al. on consumer confusion about wholegrain content and healthfulness^{(Reference Wilde, Pomeranz and Lizewski1)}. Given that the ‘discrete choice experiment’ designed by the authors contained hypothetical products that were intentionally designed to confuse consumers and are not reflective of products found in the retail marketplace, we question whether the high consumer confusion found in the study can be extrapolated to real-world scenarios. Further, we noticed several inconsistencies regarding the study design that need to be addressed.

For example, in Online Supplemental Figure 2 (a) Cereal and Online Supplemental Table 3, the ‘no treatment’ box has whole grains as the third ingredient and sugar as fifth (implying that there is more whole grain than sugar). It lists 3 g of added sugars, so one can assume that the whole grain content is greater than 3 g. In the treatment box displaying the Whole Grain Stamp (which is hardly big enough to be legible, making it difficult for study participants to fully utilise), whole grain is the sixth ingredient and sugar is second (implying that there is more sugar than whole grain). The product states that there are 13 g of added sugar and because it bears the Whole Grain Stamp, one can reason that it has at least 8 g of whole grain. However, based on the information provided by the study authors, concluding that the ‘no treatment’ cereal definitely has more whole grain than the Whole Grain Stamped cereal is faulty logic. All that can be determined from the ‘no treatment’ package is that it has more than 3 g of whole grain. The first two (non-whole-grain ingredients) could make up the majority of the product.

Unless both products bear the Whole Grain Stamp, asking study participants to compare the whole grain content of two mixed ingredient products is near impossible, because the information necessary for making that determination simply is not available. This is precisely the reason behind the creation of the Whole Grain Stamp – to truthfully report the whole grain gram amount, providing consumers with information that would otherwise be inaccessible to them. Today, the Stamp is found on more than 13 000 products in sixty-three countries around the world. The ‘level’ of Whole Grain Stamp used also helps indicate the percentage of grain ingredients that are whole. For example, if a product bears the 100 % Stamp, then all of its grain ingredients are whole grain. If a product bears the 50 %+ Stamp, then at least half of its grain ingredients are whole grain⁽²⁾. In a study designed to assess whether consumers are misled about wholegrain content and product healthfulness based on common product labels, it seems misleading on the part of the study authors not to fully utilise this widely available public health tool.

Further, the hypothetical Whole Grain Stamped products used in the discrete choice experiment are not reflective of the products that carry the Whole Grain Stamp, as the authors specifically designed them to contain lower amounts of whole grain as well as ‘nutritional disadvantages’ like sugar and Na. Of the 10 700+ products registered for the Whole Grain Stamp in the USA, 79 % of them make at least half of their grains whole, and the average gram amount of whole grain in a Stamped product is 25 g per labelled serving. This includes hundreds of products like steel cut oats, quinoa and whole wheat flours that do not contain any ‘nutritional disadvantages’ so to speak⁽³⁾. Nutrition change in public health is almost always incremental. By denigrating whole grain products that have some ‘nutritional disadvantages,’ the authors risk letting the perfect be the enemy of the good.

Additionally, by intentionally choosing four products without the Whole Grain Stamp in the Whole Grain Content Comprehension part of the experiment (see Online Supplemental Figure 4), the authors manipulated the experiment such that consumer misunderstanding was inevitable. Instead of giving consumers the opportunity to look at the product-specific gram amount shown on the Whole Grain Stamp, participants were sent on a goose chase across the front packaging, Nutrition Facts Panel, and ingredient listing and were then asked to put the whole grain content into subjective categories such as ‘contains little to no whole grain.’

Wilde et al. highlight an important challenge of nutrition education, that marketing buzzwords are not reliable indicators of how much whole grain is in a product. However, by neglecting to analyse consumer understanding within the context of whole grain labelling solutions that already exist, this study paints an incomplete picture of the food marketing landscape.