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fat the plain creams which he describes are as a rule richer than his 
fancy creams. The editor says : 
Under the head of “ Vanilla Ice Creams ” you will find instructions for mak- 
ing 9 kinds. One, a fancy ice cream, contains no milk or cream whatever. One 
is similar to New York ice cream, or frozen custard, and has a butter-fat con- 
tent of about 2 per cent. Four others roughly calculated are well under 10 per 
cent of butter fat. One shows 11 per cent, one 14, and one 17. * * * We 
find that the butter-fat content is low in the majority of ice creams. True a 
few formulas show a high percentage of butter fat in the mixture, but, on the 
other hand, we find a number of formulas for ice cream that do not call for 
any cream and we have drawn attention to one that leaves out milk as well as 
cream. It is evident that a quality standard for ice cream specifying a mini- 
mum butter-fat content, unless that minimum is low, would prevent the sale of 
many fancy frozen dainties that were sold as ice cream before hokey pokey was 
invented. * * * For anyone to say that the term “ ice cream ” covers less 
to-day than it covered fifty years ago is absurd; therefore a standard that 
requires 6 out of 10 ice creams to be sold under another name is absurd. There’s 
an old saying — not wholly untrue — that the law is an ass, but is it necessary 
in order to prevent fraud for those charged with the enforcement of the law to 
be absurd? Ice cream is a compound in which (except in rare cases) the 
principal ingredients are milk products, but if one reduces the butter-fat con- 
stituent in his compound or eliminates it and substitutes something equally 
wholesome and nourishing who shall say that he has not made ice cream as 
good as or even better than ice cream containing a specified percentage of butter 
fat? While we do not believe that a standard specifying the butter-fat content 
in ice cream is necessary to prevent fraud the establishment of a reasonable 
standard would prevent the sale of cheap frozen compounds unless they were 
plainly labeled to indicate their character, and this we believe would necessarily 
preclude their being served in individual portions, as in restaurants and at soda 
fountains. But what is a reasonable standard? Certainly not a standard 
that fixes the minimum butter-fat content above S per cent nor a standard that 
does not admit of the substitution of fresh eggs for butter fat pound for pound. 
The Kymo Company, manufacturers of food preparations, of Little 
Falls, N. Y., under date of February 25, 1907, submitted a protest 
against the standards for ice cream. The reasons for demanding a 
change are as follows: 
Inclosed, we hand you an amendment to the national definition for ice cream 
as given in circular No. 19. To our amendment we have appended an argument 
setting forth briefly numerous reasons why the present national definition 
should be repealed or amended to agree with our definition. You will find a 
recapitulation of our reasons on the last two pages of the inclosed argument. 
Because the States show a disposition to adopt the national standards we' 
deem it very important that these be as nearly right and just as it is possible to 
make them. If they are not just and right those States that accept them will 
be led into errors that will in some cases result in hardships to its citizens. On 
the other hand, those States that refuse to accept the faulty standards will 
not be in full accord with those that do, nor with the National Government in 
the very important work of suppressing the traffic in adulterated and harmful 
foods and drugs. 
If the Agricultural Department or those in control of the matter of standards 
insist upon unreasonable standards like that for ice cream, will not the public 
