Analyzing Front-of-Package Label Criteria for US Foods

The US Food and Drug Administration (FDA) is developing a front-of-package label (FOPL) system to help consumers make healthier food choices. The proposed system would use “high-in” labels for added sugar, sodium, and saturated fat, with a threshold of ≥20% of the daily value (%DV) per serving to define “high-in” content.

A study compared the FDA’s approach to three established regional nutrient profile models (NPMs): the Canadian NPM, the Pan American Health Organization (PAHO) NPM, and Chile’s NPM. Using a dataset of 51,809 US products, researchers examined how these models aligned with the FDA’s definition of “high-in” nutrients.

The study found an overall agreement of 51% for foods and 72% for beverages across the four NPMs. Agreement was highest for sweetened sodas (87%) and lowest for bread (14%) and salty snacks (29%). The Canadian NPM showed the closest alignment with the FDA criteria, while the Chilean and PAHO models had lower agreement.

Notably, the FDA’s definition would require the fewest products to carry a “high-in” label in many food categories, especially those served in small portions like salty snacks and bars. However, this trend reversed for categories with larger serving sizes, such as frozen and non-frozen main dishes.

The researchers concluded that the choice of NPM has significant policy implications for an FOPL system’s effectiveness in identifying unhealthy foods and encouraging product reformulation. They suggested that the FDA should consider adopting a more stringent NPM, similar to those used elsewhere in the Americas, when finalizing the thresholds for “high-in” labels on US packaged foods and beverages.

Commentary by YourDailyFit columnist Alice Winters:

The FDA’s proposed front-of-package labeling system represents a crucial step towards empowering consumers with clearer nutritional information. However, this study reveals significant discrepancies between the FDA’s approach and other established nutrient profiling models, raising concerns about the effectiveness of the proposed system.

The FDA’s reliance on a threshold of ≥20% of the daily value per serving to define “high-in” content appears to be a relatively lenient standard compared to other regional models. This leniency is particularly problematic for products typically consumed in small portions, such as salty snacks and bars. The danger here is that these products, often high in calories and low in nutritional value, may escape the “high-in” label despite contributing significantly to overall daily intake of sugar, sodium, or saturated fat.

The discrepancy in agreement across food categories is also troubling. With only 14% agreement for bread and 29% for salty snacks, consumers may receive inconsistent or potentially misleading information about the nutritional quality of these commonly consumed items. This lack of consistency could undermine consumer trust in the labeling system and its effectiveness in guiding healthier food choices.

Moreover, the study’s finding that the FDA’s definition would require the fewest products to carry a “high-in” label in many food categories is concerning. This approach may fail to adequately differentiate between more and less healthy options within a category, limiting the system’s ability to drive positive change in consumer behavior and industry reformulation efforts.

The reversal of this trend in categories with larger serving sizes highlights another potential flaw in the FDA’s approach. By basing the “high-in” designation solely on the percentage of daily value per serving, the system may not accurately reflect the real-world consumption patterns of these products, potentially underestimating their impact on overall nutrient intake.

The researchers’ recommendation for the FDA to consider a more stringent NPM is well-founded. Adopting standards more closely aligned with those used in other parts of the Americas could enhance the system’s effectiveness in identifying truly problematic products and encouraging meaningful reformulation efforts by food manufacturers.

However, it’s crucial to strike a balance between stringency and practicality. An overly strict system might lead to an overwhelming number of products carrying “high-in” labels, potentially desensitizing consumers to the warnings. Furthermore, it could disincentivize incremental improvements in product formulations if manufacturers perceive the standards as unattainable.

In conclusion, while the FDA’s initiative is commendable, this study underscores the need for a more nuanced and potentially more stringent approach to nutrient profiling. The final FOPL system should aim to provide clear, consistent, and meaningful information to consumers while also creating a strong incentive for the food industry to improve the nutritional quality of their products. As the FDA refines its approach, it would be wise to consider not only the percentage of daily value per serving but also factors such as typical consumption patterns, product categories, and the potential for industry reformulation. Only through such a comprehensive approach can we hope to create a labeling system that truly serves the public health interests of American consumers.