Anonymous - Comment

Evaporated Cane Juice is the common name and accurate description for a first crystallization natural or organic cane sugar sweetener. The term Evaporated Cane Juice accurately identifies the basic nature of the product and is commonly accepted by both industry and consumers. Further, we find it unlikely that consumers would consider any “evaporated juice” to be a liquid juice. ECJ has been commonly used since the early 1990s to describe this cane-derived sweetener. In our experience speaking with consumers on a daily basis, we have not see one instance of consumer confusion that ECJ is a liquid juice beverage. ECJ is known and understood as a dry, crystalline product, not a liquid juice beverage. If the percentage of juice in the product is clearly and accurately labeled, consumers should not be confused by the presence of evaporated cane juice. We therefore ask that the recent FDA guidance Docket # FDA-2009-D-0430 be withdrawn.