Guacamole dip with no avocado -- a food policy lesson in "standards of identity"

It has been fun to follow recent coverage of Kraft's guacamole dip, whose label the company changed a few months ago when people complained that the product has little avocado in it. "A thunderous 'No!' to faux guacamole," says Tom Philpott. "Yum," says Chowhound, although one suspects sarcasm after following the link to Jerry Hirsch of the Los Angeles Times (via Seattle Times):

The guacamole sold by Kraft Foods Inc. ... calls for modified food starch, hefty amounts of coconut and soybean oils and a dose of food coloring [Note 12/21: slight correction, see comments].

A column by Fortune's Marc Gunther today picks up the story of the faux guacamole as one example of "misleading labels [that] raise a bigger issue, and it's called trust." The column links to U.S. Food Policy. Gunther, who keeps a weblog and is author of Faith and Fortune, continues in today's column:

At a time when trust in big business is low - and when the food industry, fairly or not, faces escalating concern over the epidemic of obesity in the United States - you would hope, and think, that the industry would go out of its way to avoid marketing practices that are even potentially misleading.

Are there no rules about this sort of thing?

You may be surprised that it is legal to call a paste "guacamole dip" if it has minimal amounts of avocado. In fact, the federal government does have such rules, called "standards of identity," for hundreds of food products. Here is a Food and Drug Administration (FDA) announcement last year about possible changes to these standards.

Looking deep within the Code of Federal Regulations on this topic (see sections 130 to 169), I could find many related products, but no guacamole. I know you will be pleased to find that products that do have a standard of identity are required to have the nice simple ingredients you would expect.

For example, here is a brief excerpt of the long standard for "catsup":

... Such liquid is strained so as to exclude skins, seeds, and other coarse or hard substances in accordance with current good manufacturing practice. Prior to straining, food-grade hydrochloric acid may be added to the tomato material in an amount to obtain a pH no lower than 2.0. Such acid is then neutralized with food-grade sodium hydroxide so that the treated tomato material is restored to a pH of 4.20.2. The final composition of the food may be adjusted by concentration and/or by the addition of water. The food may contain salt (sodium chloride formed during acid neutralization shall be considered added salt) and is seasoned with ingredients as specified in paragraph (a)(2) of this section. The food is preserved by heat sterilization (canning), refrigeration, or freezing. When sealed in a container to be held at ambient temperatures, it is so processed by heat, before or after sealing, as to prevent spoilage....

Just like grandma used to make.