Federal Security Administrator v. Quaker Oats Co.
Annotate this Case
318 U.S. 218 (1943)
U.S. Supreme Court
Federal Security Administrator v. Quaker Oats Co., 318 U.S. 218 (1943)
Federal Security Administrator v. Quaker Oats Co.
Argued February 4, 5, 1943
Decided March 1, 1943
318 U.S. 218
The Federal Security Administrator, acting under §§ 401 and 701(e) of the Federal Food, Drug and Cosmetic Act, promulgated regulations establishing "standards of identity" for various milled wheat products, excluding vitamin D from the defined standard of "farina" and permitting it only in "enriched farina," which was required to contain vitamin B1, riboflavin, nicotinic acid and iron. The validity of the regulations was challenged as applied to the respondent, who for ten years had manufactured and marketed, under an accurate and informative label, a food product consisting of farina, as defined by the Administrator's regulations, but with vitamin D added. Under the Act as supplemented by the regulations, respondent's product could not be marketed as "farina," since, by reason of the presence of vitamin D as an ingredient, it would not conform to the standard of identity prescribed for "farina;" nor could it be marketed as "enriched farina" unless the prescribed minimum quantities of vitamin B1, riboflavin, nicotinic acid and iron were added.
Held, that the Administrator did not depart from statutory requirements in choosing the standards of identity for the purpose of promoting "fair dealing in the interest of consumers;" that the standards which he selected are adapted to that end, and that they are adequately supported by findings and evidence. Pp. 318 U. S. 220, 318 U. S. 235.
1. Upon review of an order of the Federal Security Administrator issuing regulations under § 401 of the Federal Food, Drug and Cosmetic Act, the findings of the Administrator as to the facts are conclusive if supported by substantial evidence. P. 318 U. S. 227.
(a) It is appropriate that a reviewing court accord proper scope to the discretion and informed judgment of an administrative agency where the review is of regulations of general application adopted by the administrative agency under its rulemaking power in carrying out the policy of a statute with whose enforcement it is charged. P. 227.
(b) The judgment exercised by the Administrator under § 401, if based on substantial evidence of record, and if within statutory and constitutional limitations, is controlling even though the reviewing court might, on the same record, have arrived at a different conclusion. P. 318 U. S. 228.
2. Taking into account the evidence of public demand for vitamin-enriched foods, their increasing sale, their variable vitamin composition and dietary value, and the general lack of consumer knowledge of such values, there was in this case sufficient evidence of rational probative force to support the Administrator's judgment that, in the absence of appropriate standards of identity, consumer confusion would ensue, and to support the Administrator's conclusion that the standards of identity adopted will promote honesty and fair dealing in the interest of consumers. P. 318 U. S. 228.
3. The text and the legislative history of the Act show that its purpose was not confined to requiring informative labeling, but was to authorize the Administrator to promulgate definitions and standards of identity "under which the integrity of food products can be effectively maintained" and to require informative labeling only where no such standard had been promulgated, where the food did not purport to comply with a standard, or where the regulations permitted optional ingredients and required their mention on the label. P. 318 U. S. 230.
4. The Court cannot say that such a standard of identity, designed to eliminate a source of confusion to purchasers -- which otherwise would be likely to facilitate unfair dealing and make protection of the consumer difficult -- will not "promote honesty and fair dealing" within the meaning of the Act. P. 318 U. S. 231.
5. The Act does not preclude a regulation which would exclude a wholesome and beneficial ingredient from the definition and standard of identity of a food. P. 318 U. S. 232.
6. It was not unreasonable to prohibit the addition to "farina" of vitamin D as an optional ingredient, while permitting its addition as an optional ingredient to "enriched farina." P. 318 U. S. 234.
7. On the record in this case, it does not appear that the increased cost of adding the minute quantities of the four ingredients required
for "enriched farina" is sufficient to have any substantial bearing on the reasonableness of the regulations. P. 318 U. S. 235.
129 F.2d 76 reversed.
Certiorari, 317 U.S. 616, to review a judgment setting aside an order of the Federal Security Administrator under the Federal Food, Drug and Cosmetic Act.
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