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Posted: March 2nd, 2022
Course: NFS 4160
Regulation of Granola Bars 1 DEFINITION:
Granola bars are usually referenced to as a small breakfast meal or snack. They come in a
variety flavors, forms, and textures. Granola bars are usually made up of oats or granola along a
mix of different nuts or chocolate chips- which usually gives them their varying flavors and
textures. The consistency of a granola bar is usually chewy although they can also be on the
crunchier side as well. The Department of Agriculture (USDA) generally oversees granola bars,
as well as the Federal Food, Drug, and Cosmetic Act (FD&C) and Fair Packaging and Labeling
Act (FPLA). Under the USDA, granola bars are referred to as commercial items; moreover they
contain Commercial Item Description (CID) which the USDA describes as “product descriptions
that concisely describe the most important characteristics of a commercial product” (3).
The main agency that overlooks granola bars is the USDA. However, the USDA also
contains several branches which regulate these bars. The Agriculture Marketing Services (AMS),
as well as the Federal Grain Inspection Services (FGIS), must inspect the bars to ensure
sanitation and report back to the USDA for certification if all expectations are met (3). The
process of certification is random, where samples are sent to the laboratory for analysis under
specifications for analytical testing. The selected products must meet the guidelines they fall
under for certification or approval. FD&C also looks over additives added into the bars, as well
as how much acacia is used in the formation, since it can lead to certain unique characteristics
within the bars (2). FPLA is also required for packaging purposes and must comply with the
criteria it is expected to meet.
3 ALL STANDARDS PERTAINING TO THE FOOD
For standards of identity, granola bars usually have 2 characteristics which make them
what they are. For one, they are either crunchy or chewy bars which also contain either oats,
wheat, or nuts in them. With that being said, the USDA defines them into two groups, style A
and style B bars. If the finished product of a granola bar contains either a crunchy, slightly
chewy, or granular texture it is referred to as style A with no additional classes; whereas if the
other set contains a slightly soft, chewy, or granular flavor, it is referenced as style B. Within
style B come different classes as well. Uncoated, which is class A, and coated which is class B.
As for odor and color, they must comply with the flavor they belong to and meet their claims
based on what is advertised or on the PDP (3).
4 FOOD AND NUTRITION LABELING REGULATIONS
Granola bars follow the Fair Packaging and Labeling Act guidelines.This means that the
standards of identity must comply with the product packaging, as well as net weight and
nutritional facts. Moreover, the product must be identified based on what it is, along with the
name of the manufacturer and net quantity (6). Packaging also includes a single bar package or
dual bar package, and should not exceed 90 days before being delivered to the customers (3).
5 APPLICABLE HEALTH CLAIMS
KIND bars, which is a specific brand aimed at advertising healthy bar products- usually
containing fruits and nuts rather than granola, were stopped by the FDA due to possible false
information (8). The FDA claims that KIND misbranded their bars by labeling them as healthy-
because according to the FDA, they exceed the 1 gram of saturated fat per 40g RAAC to be
labeled as such (9). According to the FDA, saturated fats should not exceed 15% of the total
calories if it were to be labeled “low in saturated fat” (9). On the other hand, KIND bars aren’t
the only ones put on the spot. Many consider granola bars a healthy snack, however there have
been numerous contradictions to many company health claims that oppose the claim “healthy”
on the labels. For example, brands like Kellog are supposed to promote healthy breakfast bar
products, however their sugar content exceeds the recommended amount. For a bar to be healthy,
sugar content should only make up 10% of the total calories (10). Exceeding these limits leads to
increased risk of chronic disease- varying from obesity to diabetes, as well as a potential risk for
heart disease (10). On the other hand, some products utilize alternative sweeteners to minimize
the risk for such health complications, and amongst those sweetners are sugar alcohols, which
were shown to carry out a less harmful risk for diabetes and other health complications. So to
avoid health complications, consumers must take into account that not every claim on the PDP is
true by reading the actual nutrition label as well as ingredient list.
6 SAFETY ISSUES
According to the Food Safety News, General Mills released a food recall on Natures
Valley granola bars due to possible listeria contamination. There were four specific products
pertaining to this recall that were recalled and consumers were noticed on the FDA website about
this issue (7). On the other hand, there was also a recent recall for granola bars this year due to
possible salmonella contamination by The Michigan-based Thumb Oilseed Producers’
Cooperative. The recall was aimed at grits and flours that were possibly incorporated into the
bars and can lead to hazards if consumed (11). To better solve the recall issue, they also stopped
producing and distributing the products and worked with the USDA and Michigan Department
of Agriculture to investigate the products(11) . Another topic I want to bring up in terms of
safety are GMO’s. GMO’s are also amongst the common concerns of some people that may lead
to minimizing product safety for consumers based on where they stand .Although they are
debatable, there have been some possible reported side effects of them. According to Medical
News Today, consuming GMOs for a long time may contribute to cancer, can trigger allergies,
and may affect antibacterial resistance (12). Although these are all possibilities, it has been
mentioned that there isn’t much research to draw a solid conclusion on these claims. However,
some bars make sure they don’t use GMO’s to maintain product credibility within consumers,
and post that on their labeling package to ensure consumers that the product is safe for them if
they have any doubt.
7 YOUR ASSESSMENT
For my assessment, I will be evaluating Market Panty (by Target) chewy granola bars
versus Quaker Oats chewy granola bars. There is a significant price difference in both products
which usually steers consumers away from getting the cheaper product. Both products advertise
being composed of whole grains on their PDP and conform to their standards of identity by being
referenced as chewy granola bars. They also both abide by the FPLA packaging guidelines in
terms of statement of identity, manufacturer’s name, and net quantity. As for nutrition labels,
there are some differences. The Quaker Oats contains 1 extra gram of whole grains (9g) as well
as no artificial flavors, colors, or preservatives. The Market Pantry chewy bars do contain
artificial flavors and preservatives, however they only contain 0.5 grams of saturated fat whereas
Quaker Oats contains 1.5 grams. The total sugar content is the same, but Quaker Oats uses
brown sugar which I don’t know if it makes much of a difference. All in all, both products
pertain to Style A bars as labeled by the USDA, since they are only chewy bars. They also come
in single bar packaging and their colors are as presented on the PDP image.
1. About AMS | Agricultural Marketing Service. (n.d.). Retrieved October 24, 2020, from
2. CFR – Code of Federal Regulations Title 21. (n.d.). Retrieved October 24, 2020, from
3. COMMERCIAL ITEM DESCRIPTION. (2003, January 10).
4. Commercial Item Descriptions | Agricultural Marketing Service. (n.d.). Retrieved
October 24, 2020, from https://www.ams.usda.gov/grades-standards/cids
5. Federal Grain Inspection Service | Agricultural Marketing Service. Retrieved October 24,
6. Fair Packaging and Labeling Act: Regulations Under Section 4 of the Fair Packaging
and Labeling Act. Federal Trade Commission.
7. Seattle, F. S. N. 1012 F. A. F. F., & Washington 98104-1008. (2016, June 25). Listeria
concerns prompt recall of Nature Valley granola bars. Food Safety News.
8. FDA Decides to Let KIND Call Its Bars “Healthy” Again. (n.d.). Time. Retrieved
October 25, 2020, from https://time.com/4324042/kind-bars-healthy-fda/
9. KIND, LLC – 03/17/2015. (2019, December 20). U.S. Food and Drug Administration.
10. Healthy Granola Bars: Fact or Fiction? (n.d.). Healthline.
11. Seattle, F. S. N. 1012 F. A. F. F., & Washington 98104-1008. (n.d.). granola bar. Food
Safety News. Retrieved October 25, 2020, from
12. Pros and cons of GMO foods: Health and environment. (n.d.).
9 ADDITIONAL/SUPPLEMENTAL MATERIAL
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