By Dr. Lory Reveil, Senior Director of Scientific and Regulatory Affairs
The American Frozen Food Institute (AFFI) supports efforts to help consumers choose foods that meet their family’s needs and overcome barriers to healthy eating. That’s why we recently submitted comments to the U.S. Department of Agriculture’s Food & Nutrition Service (USDA FNS) which call for the mandatory inclusion of frozen fruits and vegetables in the Special Supplemental Nutrition Program for Women, Infants and Children (WIC).
In November, USDA released a proposed rule for WIC food package updates. USDA recognized the important need to encourage more consumption of fruits and vegetables and proposed an increase in funds directed toward their purchase. Given that positive development, we were disappointed to see USDA undercut its effort by limiting the ways that WIC recipients can access fruits and vegetables. The USDA proposal requires states to include fresh but only allows one other form (frozen, dried, or canned). This proposal undeniably and unfortunately positions fresh produce as best for consumers. By limiting access to affordable, convenient and easy to prepare frozen produce that is available year-round and is equally nutritious as fresh produce, USDA fails to recognize the important role of frozen fruits and vegetables in supporting nutrition goals. The proposal also fails to align with recommendations from the Dietary Guidelines for Americans which state that all forms of nutrient-dense food – including fresh canned, dried, frozen and 100% juices – can be included in healthy dietary patterns.
In our comments, AFFI provides four recommendations to improve and modernize the WIC program:
- The WIC program should promote parity of healthful foods in all temperature states and forms (frozen, fresh, dried, or canned) to ensure equity, accessibility, and affordability year-round.
To help consumers choose foods that meet their family’s needs and overcome barriers to healthy eating, nutrition incentive programs such as WIC should include frozen food.
Frozen food helps households due to its cost efficiency, reduced preparation time, and easy to follow cooking instructions. Additionally, frozen food requires minimum equipment or cooking skills and is an essential part of food and nutrition access.
This has a significant impact on nutrition equity. Analysis of National Health and Nutrition Examination Survey (NHANES) data demonstrates that low-income individuals consumed less frozen fruits and vegetables than those with higher income. At the same time, a report from USDA’s Economic Research Service showed that the Low-Cost Thrifty Food Plan could be achieved for a family of four utilizing canned, frozen, fresh and dried varieties. Increased access to frozen food stands to enhance the nutrition and diets of those who need it most.
- The WIC program should recognize the importance of recommending all forms of produce to increase consumption of fruits and vegetables, as well as the importance and relevance of produce consumption during pregnancy, lactation, and the birth to 24-month populations.
Our country is facing a produce consumption crisis among people of all ages. The Dietary Guidelines for Americans Advisory Committee (DGAC) found that 9 in 10 of Americans do not eat recommended amounts of fruits and vegetables. In addition, 64 percent of pregnant and 90 percent of lactating women do not consume recommended amounts of fruits and vegetables. Furthermore, a recent Centers for Disease Control and Prevention study shows that among children aged 1-5 years, one half do not eat a daily vegetable and more than one half do not eat a daily fruit.
Increased access to frozen food can help Americans overcome these setbacks. Current knowledge indicates that exclusively recommending one form of fruit or vegetable over another ignores the benefits of each form and limits consumer choice. Research from the Produce for Better Health Foundation (PBH) shows that messages with inclusive language (recommending all forms of produce) reinforce the perceived healthfulness of packaged fruit and vegetables, including frozen produce, and increases consumers intent to purchase them.
- The WIC program should focus on evidence-based attributes, such as nutrient density, while avoiding arbitrary attributes like fresh or processed foods.
AFFI strongly encourages USDA to not discriminate against foods based on processing or temperature state, which are not immediate indicators of healthfulness. Freezing is simply nature’s pause button and locks in the freshness and nutrition of fruits and vegetables. Studies show that frozen fruits and vegetables are as rich in nutrients, and in some cases more so, than their fresh counterparts.
- The WIC program should promote a sustainable food system that minimizes food waste.
Frozen food also plays a critical role in helping to fight food waste due to its extended shelf life and pre-portioned servings. This translates to both environmental and cost benefits for consumers. Reduced food waste means reduced GHG emissions from landfill usage, and the frozen product state also reduces the possibility of waste between processing, distribution and retail. This also helps as consumers throw out up to $2,275 worth of food each year. AFFI consumer research shows that over 80% of lower-income households say they cannot afford food waste – and frozen food directly helps them avoid that problem.
It is critical for WIC packages to offer pragmatic and feasible solutions for healthy eating habits and long-term well-being, and the frozen food industry can be an important partner in helping individuals increase their produce consumption. We look forward to working with USDA to further improve upon WIC and helping families enjoy year-round access to nutrition.
 Centers for Disease Control and Prevention, National Center for Health Statistics (CDC-NCHS). National Health and Nutrition Examination Survey, 1999-2000 and 2001-02, data downloaded from http://www.cdc.gov/nchs/ nhanes.htm, 2005.
 Stewart H., Hyman J., Carlson A., Frazao, E. The Cost of Satisfying Fruit and Vegetable Recommendations in the Dietary Guidelines. USDA, Economic Research Service. Economic Brief No. (EB-27) 17 pp, February 2016. http://www.ers.usda.gov/media/2023016/eb27.pdf
 Dietary Guidelines Advisory Committee. 2020. Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services. U.S. Department of Agriculture, Agricultural Research Service, Washington, DC.
 Hammer HC, Dooyema CA, Blanck, HM, et al., Fruit, Vegetable, and Sugar Sweetened Beverage Intake Among Young Children, by State – United States, 2021. MMWR Morb Mortal Wkly Rep 2023;72:165-170. DOI: http://dx.doi.org/10.15585/mmwr.mm7207a1.
 Produce for Better Health Foundation. The Impact of Policy Recommendation with Limiting and Inclusive Language on Consumers Perceptions and Intent to Purchase Fresh and Packaged Forms of Fruits and Vegetables. Consumer Message Testing Research. October 2015. Available at: https://fruitsandveggies.org/research/.
 Li, Linshan & Pegg, Ronald & Eitenmiller, Ronald & Chun, Ji-Yeon & Kerrihard, Adrian. (2017). Selected nutrient analyses of fresh, fresh-stored, and frozen fruits and vegetables. Journal of Food Composition and Analysis. 59. 10.1016/j.jfca.2017.02.002.
 Bouzari A, Holstege D, Barrett DM. Vitamin retention in eight fruits and vegetables: a comparison of refrigerated and frozen storage. J Agric Food Chem. 2015;63(3):957-962. doi:10.1021/jf5058793
 Bouzari A, Holstege D, Barrett DM. Mineral, fiber, and total phenolic retention in eight fruits and vegetables: a comparison of refrigerated and frozen storage. J Agric Food Chem. 2015;63(3):951-956. doi:10.1021/jf504890k