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February 10, 2005 Hon.
Deborah Platt Majoras, Chairman
United States Federal Trade Commission
600
Pennsylvania Avenue NW
Washington DC 20580 Dear
Ms Majoras: The
National Grange is writing to express our grave concern about Johnson & Johnson's
marketing and advertising of the chemical sweetener sucralose, known commercially
as Splenda. This advertising campaign may be deceptively leading consumers to
believe that the artificial and chemically derived food product they are eating
is a natural product. Indeed, a recent poll conducted regarding consumer attitudes
about Splenda proves there is significant confusion among Americans about this
artificial substance. According to poll results, nearly half of all Americans
are under the impression that Splenda is a naturally-produced food, akin to sugar.
The
National Grange is the nation's oldest general farm and rural public interest
organization. Founded in 1867, today the National Grange represents individual
Grange members affiliated with 3000 local, county and state Grange chapters across
the country. We are concerned that left unchecked, well funded, potentially deceptive
and misleading corporate advertising practices, such as those used to promote
Splenda as a "natural" product will eventually erode the implicit bond of confidence
in production practices and quality assurance that family farmers have been working
to build with consumers for decades regarding the agricultural products they grow
and nurture.
In the U.S., Splenda is manufactured in a chemical plant in Alabama. Reports from
the Environmental Protection Agency reveal that five separate toxic chemicals,
among other substances, go into creating sucralose. This chemical manufacturing
gives Splenda an intensely sweet taste because chlorine atoms artificially forced
into natural sucrose molecules cause the resulting sucralose to attach unnaturally
to a person's tongue. As a finished product, Splenda contains no elements of natural
sugar whatsoever. It is made in a chemical plant, not by nature in a sugar cane
or sugar beet field.
Despite the messages that seem to be conveyed in advertisements ("Made from Sugar
so it Tastes like Sugar", "Splenda and Spice and Everything Nice", etc.) it is
a fact that Splenda still contains the industrially manufactured ingredient sucralose.
The messages contained in Splenda advertising appear to potentially confuse consumers
about this fact. The
National Grange requests that the Federal Trade Commission open an investigation
into Johnson & Johnson's marketing and advertising practices for the artificial
sweetener Splenda (sucralose) in order to determine if any of their advertising
claims are deceptive or misleading to consumers. The National Grange believes
that there should be greater clarity in the market place regarding this highly-processed,
artificial sweetener that millions of Americans are feeding their families, unaware
of the reality of what this substance actually is.
Sincerely,
Leroy
Watson, Legislative Director
National Grange of the Order of Patrons of Husbandry
cc.
Mary K Engle, Associate Director
Advertising Practices Division of the Bureau
of Consumer Protection | 
