The U.S. Food and Drug Administration (FDA) published proposals to update the design and content of the Nutrition Facts label (NFL) and associated serving sizes on Feb. 27, 2014. Two factors driving the FDA changes are undeniable: consumers’ expressed desire for the labels to be easier to read and use; and outdated nutrition science and food consumption data that supported the 1993 regulations.
Consumer research shows that more than half of food shoppers are using nutrition labeling (IFIC, 2013; Todd, 2014). Even so, within the first years of use of the NFL, 70% of consumers expressed the need for the labels to be easier to read and use (Kristal, 1998; FMI, 1995). Evolving nutrition science, including new Dietary Reference Intakes (DRIs), updated nationwide food consumption data, and up-to-date comprehensive, evidence-based Dietary Guidelines recommendations warrant changes.
Understanding that on some level the NFL is destined to change, food manufacturers have a key role in helping to shape the changes. Food manufacturers should be poring over the proposals and preparing public comments. It is also the time to develop a broader strategy for assessing entire product portfolios based on the high probability that changes will occur with final rules that could be completed by the end of 2015.
Analyses of the food and nutrient contents of the company’s brands will tell you about changes relative to the Reference Amounts Customarily Consumed (RACCs) and serving size rules, and help estimate the impact of the potential changes to Daily Values and how nutrient content claims may be affected. Part of this component is to determine how to deal with challenging aspects of the proposals that apply to all labeled foods, i.e., added sugars, which will mean accommodating new analytical and recordkeeping methods. The strategy should also include a regulatory perspective by constructing mock-ups of labels modified to reflect the proposed design requirements, to validate claim opportunities, and answer questions about how to comply with the proposed rules.
A third component of a strategy is to develop a roadmap for the company’s product portfolio and brand messaging to position and plan around a new NFL in a way that will effectively communicate to consumers, nutrition educators, and other audiences about the new nutrition information to ensure that brands and foods are perceived and used in the way that is intended. Food manufacturers should also be looking at the NFL changes in a holistic way by considering opportunities for reformulating food products (e.g., to “swap-in” healthier ingredients), creating new approaches to packaging, and new ways to give portion guidance. The work shouldn’t stop there. Aligning ingredients statements and other label features, including romance copy, make the reaction to the NFL proposals a comprehensive undertaking, which should be expected for what will likely be the most extensive nutrition policy change in decades.
FMI (Food Marketing Institute), 1995. Shopping for Health 1995. New Food Label, Same Eating Habits? Washington, DC.
IFIC (International Food Information Council Foundation), 2013. The 2013 Food & Health Survey: Consumer Attitudes Toward Food Safety, Nutrition, and Health.
Kristal, A.R., Levy, L., Patterson, R.E., Li, S.S. and White, E., 1998. J. Public Health. 88: 1212–1215.
Todd, J., 2014. Changes in Eating Patterns and Diet Quality Among Working-Age Adults 2005–2010; ERS, USDA.
Robert C. Post, Ph.D.
Chief Science Officer
Food Label Compass: http://www.foodminds.com/