What about some kind of fraud/false-advertising catch-all? Do we really need to wait for popularity in order to have a more generic regulation?

There are multiple ways to come at the problem, we could just say that the species origin of any oil included at greater than 1% concentration is required to be labeled in the ingredients and any oil not composed of greater than 95% concentration of single source must be labeled as "mixed"

I'm sure the legalease version of the above is a 100 page doc, but the FDA does provide similar generic rulings.

We're better off without any FDA standards of identity. Even maxerickson isn't asking for one; he's asking for a regulation that limits the use of ingredient names in general, not the names of individual products specifically. There is no public interest -- not in the sense of improving public welfare, and not in the sense of public demand -- in FDA standards of identity.

Standards of identity made the news recently, when the FDA granted an obvious petition after thinking for just 24 years: https://reason.com/2022/01/12/the-fda-finally-liberates-fren...

I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is probably not really problematic... straightforward concrete rules about the point you can no longer call the product "avocado oil" because it's so much something else are to me a perfectly reasonable exercise of the government's power. To some degree this kind of thing is at least theoretically covered by existing general provisions, but enforcement is likely to be laxer than necessary where the "line" is fuzzy and there's a likelihood of litigation over it.

This is especially true for cooking oil, a major part of the differentiation between types and grades of oil is down to health benefits the consumer can't really detect on their own. Having solid rules that allow simple comparisons of the labeling that actually provide useful workable information is just providing the necessary framework for consumers to make informed choices.

This is different from, say, being able to tell whether or not you like your frozen cherry pie in the absence of the puzzlingly unique and specific frozen cherry pie food standard. We definitely have a variety of legacy standards that aren't productive.

> I think standards of identity (or other FDA action that isn't necessarily a standard of identity) for things like single-ingredient products like these oils is probably not really problematic... straightforward concrete rules about the point you can no longer call the product "avocado oil" because it's so much something else are to me a perfectly reasonable exercise of the government's power

So, the minor point is that this isn't a standard of identity. It'd be something different.

The more important point is that what you're talking about doesn't make sense. There is no particular reason to think that "avocado oil" is a single-ingredient product any more than you would think the same of "pomegranate juice". By volume, most juices are apple juice or grape juice, for the excellent reason that, in order to even be palatable to most consumers, pomegranate juice (for example) requires heavy dilution. Apple and grape juice are used because their flavors are so weak. But you're not getting ripped off when you buy pomegranate juice; you're getting exactly what you want.

The place to note that something is a single-ingredient product is in the ingredients list, like here: https://www.amazon.com/Kevala-Avocado-Oil-Fluid-Ounce/dp/B00... . And if the ingredients list is fraudulent, that isn't the same problem as the fact that some people are aesthetically opposed to the product's name.

I agree that the basic "authenticity" part of this situation (where the product in fact claims to be entirely avocado oil and isn't) is already covered by existing authorities, and is basically a different problem.

As for the rest of your post, well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place. My grocery store store brand will also sell you something like "No Sugar Added 100% Juice Cranberry Pomegranate" followed by very small letters reading "flavored blend of 5 fruit juices with added ingredients"... Welch's settled a lawsuit several years for doing this very thing with a product that at least was being even a little more up-front about being primarily white grape juice.

As for there being no reason for people to think that something is what it claims to be, well I suppose that is a widely held belief that accounts for much of what we see in food labeling. I happen to think if you sell something that's 99% soybean oil and 1% avocado oil you shouldn't be able to call it "avocado oil" even if you are correctly listing the soybean oil first on the ingredients list. Or if it's 50/50 or 49/51 (and you can therefore list the avocado oil first) for that matter.

Ultimately names do matter. There's a reason the manufacturers care at all about what they're able to call their products, because it does actually affect how consumers act. Feel free to sell an otherwise accurately labeled 50/50 blend, just actually call it a blend. I really don't think it's unreasonable that if you give something an unqualified name of something that is a single ingredient that consumers should expect it to in fact be that thing.

> well for one, "pomegranate juice," a product you buy that's 100% pomegranate juice and nothing else, isn't exactly uncommon: Pom Wonderful sells it all over the place.

You're saying it's widely available. I'm saying it's not widely consumed.

And I stand by my opinion that naming a blended product after its most prominent flavor is both normal and desirable. But I see no issue with requiring blends to be labeled as blends. The regulation described sidethread here ( https://news.ycombinator.com/item?id=30106290 ) seems pretty reasonable to me.

> 1. The indication of the quantity of an ingredient or category of ingredients used in the manufacture or preparation of a food shall be required where the ingredient or category of ingredients concerned:

> (a) appears in the name of the food or is usually associated with that name by the consumer;

> (b) is emphasised on the labelling in words, pictures or graphics; or [another clause]

But even in that case, you're free to sell something as "avocado oil" when it's 50% avocado-derived or even 20% avocado-derived [consider something like "garlic olive oil"]; you just need to disclose the amount.

I'd say "garlic olive oil" is a different category where its name already implies a mixture of these two things, and from that name you'd expect the resulting product to contain both garlic and olive oil, and be mostly olive oil (and would be mislabeled if it's actually artificial garlic flavor, or actually canola). It's the unqualified naming that I'm objecting to, in general.

Anyway, I think the EU regulation quoted sounds pretty reasonable also, assuming something about how reasonably prominent such information would need to be.

> I'd say "garlic olive oil" is a different category where its name already implies a mixture of these two things, and from that name you'd expect the resulting product to contain both garlic and olive oil

OK, granted, but that isn't true of "chili oil". It could refer to oil pressed from chili, but it doesn't.