Cookie with omega-3 and fiber claims

The package for an oat and seed cookie makes claims of "powered by... omega-3s and fiber"...

 

The Nutrition Facts show only 2 g fiber, so no nutrient claim, even if just "implied," can be made for fiber (because the product isn't even a "good source" of fiber at this level). As for omega-3 content, there is no established Daily Value for omega-3 fatty acids in labeling of US foods, so no claims can be made. The product could show omega-3 content as an optional nutrient, but they haven't even done that, so there is no way to know how much omega-3 is in one serving of the product, which would be required for even a quantitative mention of the nutrient (e.g., "contains X grams omega-3). Additionally, the presumed source of the omega-3 fats, flax seeds, is in the form of whole seeds, rather than ground, so there is questionable bioavailablity of the omega-3 (the body cannot make use of it, as most of the fats will pass through the digestive system without being absorbed).

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