A Whole Grain Label Doesn’t Tell the Whole Story

By Marion Nestle & Lisa Sutherland

World renowned food politics expert Marion Nestle joins forces with former cereal executive Lisa Sutherland to examine what cereal boxes reveal about American culture and food politics in their book Sugar Coated: Unboxing the Hidden Forces Shaping America’s Favorite Breakfast Food.

[Editor’s note: We know from our research on the longest-living people in blue zones areas that whole grains play a crucial role in their diets. About 65% of their diet is made up of whole grains, beans, and starchy tubers. Grains including oats, barley, brown rice, and ground corn are most common and are typically consumed in less processed ways such as oatmeal, cooked barley in soups, brown rice, and nixtamal tortillas.]

Breakfast cereals usually list a grain as the first ingredient (unless sugar takes that spot). Grains are the edible seeds of the Poaceae family of grasses, which includes oats, wheat, corn, and rice—90% of all cereals. Quaker Oats has been oat based since its start. General Mills relies largely on wheat (Wheaties), oats (Cheerios), and corn (Kix). Kellogg started out with wheat and corn cereals, then added rice (Rice Krispies). Post often combines grains, such as corn and oats, in Honey-Comb and Oreo O’s. Boring as they might seem, grains are the focus of intense competition. Witness the grain wars: General Mills’ focus on whole grains versus Kellogg’s on fiber.

General Mills: Whole Grain Nation

Whole grains are demonstrably good for health. Because of their nutrients and fiber, they are strongly associated with a reduced risk of premature death from all causes, including coronary heart disease. You might think whole grains would be an obvious way to sell cereals, but most breakfast grains are so highly processed that hardly any fiber or nutrients remain. For cereal manufacturers, using whole grains poses challenges in processing, texture, and taste. Intact or minimally processed whole grains are hard to eat and digest. Nearly everybody prefers the taste and texture of refined-grain foods—white bread as opposed to whole wheat.

Turning seeds into easily digestible cereals with broad consumer appeal requires grinding, crushing, and further processing (“refining”) to remove most of the bran and germ. Refining, unfortunately, removes most of the fiber and nutrients, which is why some are added back through fortification. Thus, General Mills refines whole oats into oat flour and sends it to manufacturing facilities to produce Cheerios, which has few nutrients except those added back through fortification.

General Mills’ use and promotion of whole grains dates back to some of its first cereals: Washburn’s Whole Wheat Flakes, now Wheaties (1921), and whole-grain oat Cheerios (1941). Over the next five decades, the company introduced highly refined sugary cereals such as Trix, Lucky Charms, Cocoa Puffs, and Cinnamon Toast Crunch, none a particularly healthy or obvious way to consume whole grains. Although General Mills experienced decades of record growth for its Big G cereals, sales slowed by the mid-1990s. The company needed to innovate. Whole grains seemed like a good way to attract health-conscious consumers, especially the aging baby boomer population.

General Mills’ first attempt to push whole grains followed the Food and Drug Administration (FDA) Modernization Act of 1997, which allowed companies to use health claims backed up by reports from federal agencies or the National Academy of Sciences (NAS). Companies merely had to notify the FDA when they wanted to use a claim; they could use it if the agency did not object within 120 days. In 1999, General Mills petitioned the FDA for a claim that whole-grain foods could reduce the risk of heart disease and certain cancers, based on the NAS’s 1989 report Diet and Health: Implications for Reducing Chronic Disease Risk. The FDA consulted with the NAS but chose to take no action. As soon as the 120 days were up, General Mills exulted: “The FDA agrees that eating whole-grain foods like Cheerios, Wheaties, and Total . . . may reduce your risk of heart disease and some cancers.” The FDA’s nonaction launched two decades of intense whole-grain marketing. By 2000, General Mills led the cereal category for the first time with a 33% share and touted its “healthy innovation” as a primary reason for its reinvigorated growth.

In 2003, General Mills became a founding member of the Whole Grains Council, an entity managed by Oldways Preservation and Exchange Trust, a group founded in 1990 as a think tank on food issues. The council was, and is, supported by food industry members. It ran an education campaign to encourage increased whole-grain consumption.

Shortly after joining the council, General Mills announced that it would soon convert all its Big G cereals, including sugary kids’ cereals made mostly from refined grains, to “good” or “excellent” sources of whole grains. Its boxes stated the whole-grain promise, “ALL General Mills Cereals Are Made With WHOLE GRAIN!” These boxes also displayed “goodness corners” with icons promoting a variety of nutrition qualities; one showed a wheat shaft and stated whether the cereal was a “good” or “excellent” source of whole grain.

One problem: although the FDA had defined the meaning of good and excellent for nutrients, it had not done so for whole grains—a food ingredient. To solve that problem, General Mills petitioned the FDA to define the claim. It suggested its own cut points: “excellent” (16 grams whole grains per serving), “good” (8 grams), and “made with.” When the FDA rejected the petition, citing the absence of a defined Daily Value (DV) for whole-grain consumption, the company had to remove the whole-grain icon and the unauthorized claims. But it continued to relentlessly promote whole grains.

The workaround: The Whole Grain Stamp

At about that time, the Whole Grains Council created a bright-gold Whole Grain Stamp as an “aid for busy shoppers”. The first stamps followed General Mills’ lead. They defined a “good source” as at least 8 grams per serving and an “excellent source” as 16 grams, and they added a third category, “100% excellent” (all grains whole and at least 16 grams). An advertising campaign promoted “Trust the Stamp” on television, in magazines, and in newspapers. The first products displaying the stamp appeared in supermarkets in 2005. General Mills put the stamp on many of its cereals, including kids’ cereals like Cocoa Puffs and Lucky Charms, despite their 12 grams of sugar and only 1 gram of fiber. Within a year, nearly 50 companies were using the stamp on more than 550 products.

So where was the FDA? It immediately objected, since it still had not defined “good” or “excellent” sources of whole grains. Under pressure from companies and consumer groups, the FDA developed Whole Grain Guidance for Industry in 2006, which was voluntary and not enforceable. This suggested that label statements should not imply comparative levels of whole grains (like good or excellent), as such comparisons would be false and misleading. Instead, the FDA suggested companies use factual statements like “xx% whole grain” or “xx grams of whole grain.”

The Whole Grains Council complained that “the FDA’s nonbinding recommendations, released today, are a guidance document, which does ‘not establish legally enforceable responsibilities.’” True. But it had to comply.

The Center for Science in the Public Interest (CSPI) disapproved of the Whole Grain Stamp. It called on the FDA to focus resources on “the most common type of deceptive labeling—misleading whole grain claims.” CSPI argued that without identifying the actual percentage of whole grains, the stamp could not help anyone interpret dietary advice to make half your grains whole. It also could mislead consumers into eating more refined grains, since it allowed claims for products containing only 8 grams of whole grains in a 30-gram serving (27% whole grain but 73% not whole grain). Most troubling, the stamps appeared on sugary kids’ cereals, making them seem healthier. CSPI urged the FDA to insist that the stamps include the actual percentage of whole grain and the number of grams.

Despite CSPI’s objections, the FDA has issued no further guidance or regulations for labeling whole grains, and General Mills continues to use the Whole Grain Stamp on cereals like Cocoa Puffs, Trix, and Lucky Charms. In 2025, the Whole Grain Stamp appeared in three versions:

• 100% whole grain: minimum 16 grams, all grains whole
• 50%+ whole grain: minimum 8 grams, at least half the grains whole
• Basic: at least 8 grams but contains primarily refined grain

A basic stamp might say “Whole grain 8 g or more per serving,” with the admonition “Eat 48 g or more of whole grains daily.” The program is voluntary. Companies self-determine whether their products qualify for the stamp; the program runs on the honor system. They pay to use the stamps through membership fees to the Whole Grains Council. In 2024, these ranged from $525 per year for small companies with sales up to $500,000, to $15,750 per year for companies with sales exceeding $1 billion. The Whole Grains Council says it represents more than 350 companies, and its stamps appear on more than 13,000 products in 64 countries.

Whole grains in dietary guidance

General Mills repeatedly petitioned the FDA to allow it to market whole-grain cereals as nutritionally superior despite their sugar content. It also lobbied for dietary guidelines that called for consumption of whole grains (and, therefore, General Mills’ cereals). For the first time, the 2005 Dietary Guidelines did just that: “In general at least half the grains should come from whole grains.” The guidelines advised Americans to eat three or more “ounce-equivalent servings of whole grains per day,” meaning 16 grams each, for a total of 48 grams per day.

General Mills declared victory and launched its Whole Grain Nation marketing campaign, which included TV and print ads and a dedicated website (now gone). When the US Department of Agriculture (USDA) issued a new Food Guide Pyramid to accompany the 2005 guidelines, General Mills put a banner on the Frosted Cheerios box we show in Figure 8: “New Pyramid Recommends More WHOLE GRAIN!” It followed this statement with “For more info go to MyPyramid.gov,” implying government endorsement. The back of the box said, “9 out of 10 Americans don’t get enough whole grain” and “Aim for at least 3 servings of whole grain each day.” The eat-more-cereal message could not have been more explicit.

This article was excerpted from Sugar Coated: Unboxing the Hidden Forces Shaping America’s Favorite Breakfast Food. Copyright © 2026, Marion Nestle & Lisa Sutherland. Reproduced by permission of University of California Press. All rights reserved.