News Flash: According to the FDA, Chewing Gum Is Food

GUM ~ Seattle Gum WallPhoto Credit: vikisuzan on flickr. Click picture to go straight to original photo.

Wait, what?! I know. That's what I said, too.  I got up this morning with the vague idea that I would talk about the perils of designating some foods as good and others as bad.  To that end, I channeled my Keen Researchy Skills to look up the definition of food. Turns out, there are Loads of definitions for food.  See?

Material consisting essentially of protein, carbohydrate, and fat used in the body of an organism to sustain growth, repair, and vital processes and to furnish energy; also : such food together with supplementary substances (as minerals, vitamins, and condiments)

any substance containing nutrients, such as carbohydrates, proteins, and fats, that can be ingested by a living organism and metabolized into energy and body tissue--The Free Dictionary

any substance, usually of plant or animal origin, consisting of carbohydrates, proteins, fats, and such supplementary elements as minerals and vitamins, that is ingested or otherwise taken into the body and assimilated to provide energy and to promote the growth, repair, and maintenance essential for sustaining life. --Free Online Medical Dictionary

Material, usually of plant or animal origin, that contains or consists of essential body nutrients, such as carbohydrates, fats, proteins, vitamins, or minerals, and is ingested and assimilated by an organism to produce energy, stimulate growth, and maintain

A material that can be ingested and utilized by the organism as a source of nutrition and energy.--McGraw Hill Dictionary of Scientific & Technical Terms via The Free Dictionary

Any nutritious substance that people or animals eat or drink, or that plants absorb, in order to maintain life and growth.--Right on the Google Search page for my query "definition of food"

Keep in mind, those are all the first of several available definitions.  For each entry, each had a second or third meaning that is something along the lines of "nutriment or nourishment in solid form."

Then, I wondered if there were a Legal definition for food.  I mean, I thought surely the FDA would provide an Excellent Definition of food.  What I found was...shocking? Upsetting? A sign of the End Times? You decide. Here is said definition:

"Food means a raw, cooked or processed edible (?!) substance (Mmmm, edible substances. Like pink slime?), ice (?), beverage (?) or ingredient used or intended for use or for sale in whole or in part for human consumption, or chewing gum(?!?!?!)" (Italics and histrionic punctuation mine) --FDA Food Code, 2009 (most recent code)

Dear Lord, no wonder we are One Messed Up Nation. Before you EU people start feeling all pleased with yourselves, here's the EU definition, including exclusions:

For the purposes of this Regulation, "food" (or "foodstuff") means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans.

"Food" includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment. It includes water after the point of compliance as defined in Article 6 of Directive 98/83/EC and without prejudice to the requirements of Directives 80/778/EEC and 98/83/EC.

"Food" shall not include:

(a) feed;

(b) live animals unless they are prepared for placing on the market for human consumption;

(c) plants prior to harvesting;

(d) medicinal products within the meaning of Council Directives 65/65/EEC(21) and 92/73/EEC(22);

(e) cosmetics within the meaning of Council Directive 76/768/EEC(23);

(f) tobacco and tobacco products within the meaning of Council Directive 89/622/EEC(24);

(g) narcotic or psychotropic substances within the meaning of the United Nations Single Convention on Narcotic Drugs, 1961, and the United Nations Convention on Psychotropic Substances, 1971;

(h) residues and contaminants.--EUR-Lex

But you know what?  At least the EU definition has exclusions. I didn't see any in the FDA definition, although to be fair, they could be listed elsewhere.  (I guess that hash brownies are not considered food in the EU, but in the US, they are.  I further guess that you are allowed to feel at least a Smidge Smug, EU people).

Looking back at the dictionary definitions, they all had a few things in common. One that jumps out is that every definition includes the positive effect on the body that food has: "provide energy," "to maintain life and growth," "a source of nutrition and energy."  According to all the dictionary definitions, food is supposed to be good for us. Duh, right?

But take a look at the FDA definition. There are so many things wrong with it that I think my fingers shall tire before I finish typing:

  1. Nowhere does the FDA definition state the positive benefits of food. Neither nourish nor sustain is included in the definition.
  2. Edible does not equal nutritious.  Edible just means that something can be eaten. Note that it doesn't mean that just because it can be eaten that it should be eaten.
  3. Ice is not food. Sorry, it just isn't. Unless you're the FDA. Or the ice lobby. (it could be a real thing)
  4. Beverages aren't food. Unless you're talking about Ensure. Which is probably not food. Unless you're the FDA. Or the sneaky beverage-as-food lobby. (it, too, could be a real thing)
  5. "...intended for use or for sale in whole or in part for human consumption" is just confusing and can be read many different ways: "part of the ingredient could be consumed by a human" "anything for sale to eat" "anything that has its parts sold to eat" "stuff that humans could partially eat"
  6. Human consumption, again, does not necessarily mean that just because it can be consumed that it's either nutritious or that it should be consumed.
  7. Chewing gum?????

Aside from the obvious, what other issues do I take from the stark contrast between the FDA definition of food and the definitions from Every Other Source in the Universe?  How about this: I read an interesting blog post a few months ago called 7 Reasons Starbucks in the McDonalds of Coffee over on Coffee Cup News.  The most telling reason offered was Starbucks' change in mission statement from one starting "To establish Starbucks as the premier purveyor of the finest coffees in the world..." to "to inspire and nurture the human spirit - one person, one cup and one neighborhood at a time." (Coffee Cup News, November 28, 2011. Link to post above.)

See what they did there? Starbucks--the largest purveyor of premium coffee In The World--took coffee out of the equation.  And that's exactly what the FDA has done to the definition of food. They've taken nutrition out of the equation. And added gum.

So what are your thoughts? Are you as horrified/scared/appalled as I am, or is this just governmental doublespeak business as usual? Is there anything that consumers can do to impact this definition?  And, just for "fun," why not take a spin at identifying some "foods" that strictly fit the definition but really aren't foods. Like Pop-Rocks.

That's it for now. Have a lovely day.





  1. says

    Interesting that the FDA adds the “or chewing gum” to the sentence.I find it somewhat disturbing that “ice” is termed a food as well.

    :::excerpt from FDA foodcode 2009:::
    “Food” means a raw, cooked, or processed edible substance, ice, beverage, or ingredient used or intended for use or for sale in whole or in part for human consumption, or chewing gum.

    But I do now understand the intention. The FDA is supposedly regulating all substances that are intended for humans to stuff into their gullets. Do we really want them to start making subjective decisions about what is food and what is not?

    What I’d really like to see with regards to chewing gum is a bold message on every package saying “Warning!! Could cause tooth decay and/or choking” not to mention that there should be major fines for anyone (no matter how old) who drops chewed gum onto the sidewalk and leaves it there.

    • says

       I’m with you on that one. Yes, the definition has to be broad enough to cover everything but I wish there were separate definitions for “food” and “other miscellaneous edible items” or something. 🙂

  2. says

    I’m surprisingly  okay with their definition. That specifies the scope of their authority. In other words, if something is going to be eaten, they have the authority to regulate it.

    This is the flip side of defining what is a “drug”. If something is a drug is has to pass tests for safety and efficacy. If it’s a “food supplement” it has a much lower bar to clear.

    To avoid people selling adulterated products as food — things that clearly should not be considered food — they need a very expansive definition of their authority.

    Look at it this way: If gum is not a “food”, who decides what you’re allowed to put in it?

    • says

       I understand what you’re saying, Drew. Their definition (by definition) must be very broad. But, like Elizabeth says, I wish there were a differentiation between actual food and other crap we shove in our faces.

  3. Smithf949 says

    When I originally commented I clicked the Notify me when new comments are added checkbox and now every time a comment is added I get 4 emails using the same comment. Is there any way you may take away me from that service? Thanks! gfbeedkcec

    • says

      Sorry about that. I’ll see what I can do. Fortunately for you, this post doesn’t get commented on a lot. Still, I’m sure it’s annoying. Not sure if I can de-subscribe you to comments, but I’ll check.

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