In formal comments submitted to the U.S. Department of Agriculture's (USDA) Center for Nutrition Policy and Promotion, which will be updating the Food Guide Pyramid, John R. Cady, president and CEO of the National Food Processors Association (NFPA), made the following remarks:

"Whether it be a revised Food Guide Pyramid, an update or a new graphic, food manufacturers must be able to use the graphic to illustrate to consumers how the food products they purchase 'fit' the food guidance system. NFPA believes this flexibility to responsibly depict individual foods, main dishes and meals in the food guidance graphic will encourage understanding and use of by consumers. NFPA recommends that this concept of allowing companies to depict their branded products in the food guidance graphic be thoroughly evaluated with consumers."

Several examples based on the current Food Guide Pyramid graphic describe this concept:

* Yogurt: Allow the branded yogurt product to be depicted in the graphic in the milk, cheese and yogurt group.

* Beans: Allow depiction of a bag of beans or can of beans along with other foods in the appropriate categories -- meat and meat alternate, and vegetable groups.

* Juice: Allow the graphic to depict a glass or branded carton or container of juice in the fruit group.

* Raisins: Allow depiction of a branded box or package of raisins in the fruit group.

* Canned or Frozen Vegetables: Allow depiction of branded packages of vegetables, i.e., branded frozen broccoli package or branded can of green beans in the vegetable group.

* Multi-component meal: Allow each component of a multi-component meal to be depicted in the graphic using relevant serving/portion sizes, such as chicken breast in the meat group, carrots in the vegetable group, and rice in the grains group.

"The graphic and educational components of the food guidance system should reflect the reality of how consumers purchase and consume foods -- including fresh and processed foods. It is important that consumers understand an abundant variety of processed and multi-component foods exist that provide high nutrition, convenience and consumer value.

"USDA's challenge is to foster consumer use of the current pyramid or revised graphic be equivalent to current recognition. Given the high consumer recognition of the current Food Guide Pyramid, NFPA believes that USDA should invest in refining the graphic, with the majority of resources devoted to public education materials for the food guidance system as part of the upcoming 2005 Dietary Guidelines for Americans and in conjunction with the Nutrition Facts panel on food labels."