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ATTACHMENT 4 
HEALTH CLAIMS CHART

 Approved                 Food                               Claim                                                       Model Claim                                 
 Claims                   Requirements                       Requirements                                                Statements                                  
 Calcium and              High in calcium, Assimilable        Indicated disease depends on many factors by listing risk   Regular exercise and a healthy diet with    
 Osteoporosis 101.72      Bioavailable, Supplement must               factors for the disease.                            enough calcium helps teens and young            
                          disintegrate and dissolve, and        Gender - Female                                          adult white and Asian women maintain        
                          Phosphorus content cannot             Race - Caucasian and Asian                               good bone health and may reduce their       
                          exceed calcium content.               Age - Growing older                                      high risk of osteoporosis later in life.    
                                                             Primary target population                                                                               
                                                                Females                                                                                              
                                                                Caucasian and Asian races                                                                            
                                                                Teens and young adults in their bone forming years                                                   
                                                             Additional factors necessary to reduce risk                                                             
                                                               Eating healthful meals                                                                                
                                                               Regular exercise                                                                                      
                                                             Mechanism relating calcium to osteoporosis                                                              
                                                               Optimizes peek bone @@@                                                                               
                                                             Foods or supplement containing more than 400 mg calcium                                                 
                                                               Must state that total intakes of greater than 2,000 mg                                                
                                                               calcium provide no added benefit to bone health                                                       
 Sodium and               low sodium                         Required terms                                              Diets low in sodium may reduce the risk of  
 Hypertension 101.74                                           "Sodium"                                                  high blood pressure, a disease associated   
                                                               "High blood pressure"                                     with many factors.                          
                                                             Includes physician statement (Individuals with high blood                                               
                                                              pressure should consult their physicians) If claim defines                                             
                                                               high or normal blood pressure                                                                         
 Dietary fat and Cancer   Low fat                            Required terms                                              Development of cancer depends on many       
 101.73                   Fish & game meats:  "Extra lean"     "Total fat" or "Fat"                                     factors.  A diet low in total fat may reduce 
                                                               "Some types of cancers" or "Some cancers"                 the risk of some cancers.                   
                                                             Does not specify types of fats or fatty acids that may be                                               
                                                               related to risk of cancer                                                                             
 Dietary Saturated Fat    Low saturated fat,                 Required terms:                                             White many factors affect heart disease,    
and Cholesterol and Risk  Low cholesterol, and                 "Saturated fat and cholesterol"                           diets low in saturated fat and cholesterol   
 of Coronary Heart        Low fat                              "Coronary heart disease" or "Heart disease"               may reduce the risk of this disease.        
 Disease 101.75           Fish & game meats:  "Extra lean"     Includes physician statement (Individuals with elevated                                               
                                                               blood total - or LDL - cholesterol should consult their                                               
                                                              physician) If claim defines high or normal blood total                                                 
                                                              and LDL-cholesterol                                                                                    
 Fiber-Containing Grain   A grain product, fruit, or         Required terms:                                             Low fat diets rich in Fiber-                
 Products, Fruits, and    vegetable that contains dietary    "Fiber", "Dietary fiber", or "Total dietary fiber"          containing grain products, fruits, and      
 Vegetables and Cancer    fiber, Low fat, and                  "Some types of cancer" or "Some cancers"                  vegetables may reduce the risk of some      
 101.76                   Good source of dietary fiber      Does not specify types of dietary fiber that may be related  types of cancer, a disease associated with  
                          (without fortification)              to risk of cancer.                                        many factors.                               

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24

HEALTH CLAIMS CHART

 Approved                 Food                                  Claim                                                                      Model Claim                                      
 Claims                   Requirements                          Requirements                                                               Statements                                       
                                                                                                                                                                                            
 Fruits,                  A Fruit, vegetable, or grain          Required terms:                                                            Diets low in saturated fat and                   
 Vegetables, and          product that contains fiber,            "Fiber", "Dietary fiber", "Some types of dietary fiber",                 cholesterol and rich in fruits, vegetables,      
 Grain Products That      Low saturated fat,                      "Some dietary fibers", or "Some fibers"                                  and grain products that contain some types       
 Contain Fiber,           Low cholesterol, Low fat,               "Saturated fat" and "Cholesterol"                                        of dietary fiber, particularly soluble fiber,    
 Particularly Soluble      At least 0.6 grams of soluble fiber     "Heart disease" or "Coronary heart disease"                              may reduce the risk of heart disease, a          
 Fiber, and Risk of       per RA (without fortification), and     Includes physician statement (individuals with elevated blood            disease associated with many factors             
 Coronary Heart Disease   Soluble fiber constant provided on      Total - or LDL - cholesterol should consult their physicians)                                                             
 101.77                   label                                   if claim defines high or normal blood total - and LDL -                                                                   
                                                                cholesterol                                                                                                                 
                                                                                                                                                                                            
 Fruits and Vegetables    A fruit or vegetable,                 Required terms:                                                            Low fat diets rich in fruits and vegetables      
 and Cancer 101.78        Low fat, end Good source                "Fiber", "Dietary fiber", or "Total dietary fiber"                       {foods that are low in fat and may contain       
                          {without fortification} of              "Total fat" or "Fat"                                                     dietary fiber, Vitamin A, or Vitamin C} may      
                          at least one of the following:          "Some types of cancer" or "Some cancers"                                 reduce the risk of some types of cancer, a       
                          Vitamin A, Vitamin C, or dietary        Characterizes fruits and vegetables as "Foods that are low               disease associated with many factors.            
                          fiber                                   in fat and may contain Vitamin A, Vitamin C, and dietary                 Broccoli is high in vitamins A and C, and is     
                                                                fiber"                                                                     a good source of dietary fiber.                  
                                                                Characterizes specific food as a "Good source" of one or more                                                               
                                                                  of the following:  Dietary fiber, Vitamin A, or Vitamin C                                                                 
                                                                Does not specify types of fats or Fatty acids or types of                                                                   
                                                                  dietary fibers that may be related to risk of cancer.                                                                     
                                                                                                                                                                                            
 Folate and Neural Tube   Dietary supplements, or               Required terms:                                                            Woman who consume adequate amounts               
 Defects 101.79           Foods in conventional food form       Terms that specify the relationship - {e.g., woman who are                 of folate daily throughout their childbearing    
{responds to the Dietary  that are naturally good sources of    capable of becoming pregnant and who consume adequate                      years may reduce their risk of having a          
 Supplement Act of        folate (i.e., only non-fortified      amounts of folate}                                                         child with a neural tube birth defects.  Such    
 1992}                    food in conventional food form)       "Folate", "folic acid", "folacin", "folate", "folate a B vitamin", "folio  birth defects, while not widespread, are         
                                                                 acid, a B vitamin", or "folacin, a B vitamin"                             very serious.  They can have many causes.        
                          The claim shall not be made on        "Neural tube defect", "birth defects, spinal bifida, or                    Adequate amounts of folate, a B vitamin,         
                          products that contain more than        anencephaly", "birth defects of the brain or spinal cord                  can be obtained from diets rich in fruits,       
                          100 percent of the RDI for vitamin     anencephaly or spinal bifida", "spinal bifida or                          dark green leafy vegetables and legumes,         
                          A as retinol or preformed vitamin      anencephaly, birth defects of the brain or spinal cord"                   enriched grain products, fortified cereals, or   
                          A or Vitamin D                                                                                                   a supplement.  Woman who have had a              
                          Dietary supplements shall meet        Must also include Information on the multifactorial nature and             child with a spinal cord birth defect should     
                          USP standards for disintegration      prevalence of neural tube defects, dietary sources of folate,              consult a physician before becoming              
                          and dissolution or otherwise          and the safe upper limit of daily intake                                   pregnant.  Folate consumption should be          
                          bioavailable                                                                                                     limited to 1,000 ug per day front all            
                                                                                                                                           sources.                                         
General criteria all claims must meet:  See following page.
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HEALTH CLAIMS CHART
General Criteria All Claims Must Meet:

Only information on the value that intake or reduced intake, as part
 of a total dietary pattern, may have on a disease or health-related
 condition

Enables public to understand information provided and significance of 
information in the context of a total daily diet

Complete, truthful, and not misleading

Food contains, without fortification, 10 percent or more of the Daily 
Value of one of six nutrients (Dietary supplements excepted)

 Vitamin A      500IU     Calcium   100mg 
 Vitamin C      6mg       Protein   5g 
 Iron           1.8mg     Fiber     2.5g 

All information in one place without intervening material
{Reference statement permitted)
Not represented for infants or toddlers less than 2 years of age
Uses "may" or "might" to express relationship between substance and 
diseases
        Does not quantify any degree of risk reduction
Indicates disease depends on many factors

Food contain less than the specified levels of four disqualifying 
nutrients
 Disqualifying Nutrient   Foods     Main Dishes    Meal Products 
 Fat                      13g       19.5g          26 
 Saturated Fat            4g        6g             5g 
 Cholesterol              60mg      90mg           120mg 
 Sodium                   480mg     720mg          960mg 
 
 Low Fat                                                     Low Sodium                                                  Good source of Vitamin A 
         < or = 3g per RA (And per 50 g If RA is small)              < or = 140mg per RA (and per 50g if RA is small)                 food 500 to 950 IU per RA 
         Meats and main dishes:  < 3g per 100 g inf not              Meals and main dishes:  < or = 140mg per 100g                    Meals and main dishes:  Contains food that is a 
         more than 30% of calories from fat                                                                                      good source of Vitamin A and identifies food 
 
 Low saturated fat                                           "Extra Lean"                                                Good source of Vitamin C 
         < or = 1g per RA and < or = 15% of calories from                      < 5g total fat and < 2g saturated and                       6 to 11.4 mg per RA 
         saturated fat                                               < 95 mg cholesterol per RA and per 100g                     Meals and Main dishes: Contains food that is a 
         Meals and main dishes: < or = 1g per 100g and               Meals and main dishes: <5g total fat and                    good source of Vitamin C and identifies food 
         < 10% of calories from saturated fat                        < 2g saturated fat and < 95 mg cholesterol 
                                                                     per 100 g and per SS 
 
 Low cholesterol                                             High in calcium                                             Good source of dietary fiber 
         < or = 20mg per RA (and per 50g if RA is small)             > or = 200 mg per RA                                             2.5 to 4.75 per RA 
         Meals and main dishes: < or = 20mg per 100g                 Meals and main dishes:  Contains food that is high          Meals and main dishes:  Contains food that is a 
                                                                     in calcium and identifies the food                          good source of dietary fiber and identifies food 

Abbreviations: RA = Reference Amount; SS = Serving Size; IU = International Units

ATTACHMENT 4