If you wanted to offer your two cents on how the US Food and Drug Administration (FDA) defines “healthy” food, you’ll have to keep those pennies in your pocket for now. The public comment period closed on April 26, and the people—more than a thousand in total—have spoken.
The comments represent a diverse range of perspectives. Some are purist, suggesting that all artificial colors or flavors, preservatives, and genetically engineered ingredients be excluded from foods bearing the “healthy” label. Others raise concerns about consumer (mis)interpretations of “healthy” and related terms, and recommend that its use on product labels be disallowed. Still others—primarily those representing various sectors of the food industry—advocate for flexibility in the regulations to accommodate existing products or provide adequate time for product reformulation.
As for UCS?
We pursued a science-based path to food-based criteria, emphasizing the importance of food groups in healthy dietary patterns, while also supporting limits for sugar, sodium, and fat. Some of these were no-brainers, and some were, quite frankly, tough nuts to crack. Here’s where the science steered us.
Food-based criteria are a must
Any food item labeled “healthy” should contain a substantial proportion of one or more health-promoting foods. We chose to define “health-promoting foods” generally as vegetables, fruits, whole grains, dairy (including nutritionally equivalent dairy substitutes), and protein foods. These categories largely reflect the Dietary Guidelines for Americans Key Recommendations for Healthy Eating Patterns. We also identified some specific foods that should be excluded from the healthy label: fruit juice, processed meat, and red meat. Fruit juice has a higher glycemic index than whole fruit and lacks equivalent fiber content, and is associated with a greater risk of developing type 2 diabetes. The World Health Organization’s classification of processed meat as carcinogenic to humans, and red meat as probably carcinogenic, provides the basis of their exclusion.
Establishing what constitutes a “substantial amount or proportion” of a health-promoting food is considerably more difficult. While there is some precedent for evaluating the healthfulness of foods (the Environmental Working Group Food Scores and the United Kingdom Department of Health’s Nutrient Profiling Model are good places to start), we lack substantive research to help us identify an amount that strikes the ideal balance between potential health benefits and practicality. Of course, the more health-promoting foods like fruits, vegetables, and whole grains we eat, the better; but a useful recommendation must also consider the full range of products that line our grocery store shelves and the habits and preferences of the people who buy them. Ultimately, should the FDA decide to adopt this method of classifying foods, it will need research that addresses this question.
A “healthy” food should be low in ingredients and nutrients associated with clear health risks
The inclusion of added-sugar limits in the FDA definition of “healthy” is long overdue. The 2015 Dietary Guidelines for Americans recommend that calories from added sugars contribute no more than 10 percent of total calories, while the American Heart Association limits calories from added sugar to less than seven percent of total calories for moderately active adults, and recommends that children under two avoid added sugar altogether. In keeping with the dietary guidelines, we propose that added sugar contributes no more than 10 percent of calories to a food labeled “healthy,” with greater potential health benefits offered by further reductions.
While the current definition of “healthy” identifies sodium limits for foods, research suggests that many Americans need more help staying below recommended daily levels. The current mean sodium intake in the US is 3,440 milligrams per day—that’s almost 150 percent higher than recommended intake of 2,300 mg per day. Research consistently demonstrates a strong relationship between sodium intake and risk of heart disease, which is the leading cause of death in the United States.
Given that processed and commercially prepared foods provide about 75 percent of our total sodium intake, it’s important that the FDA take this opportunity to set adequate sodium goals for packaged foods. While the available science does not point to one optimal sodium threshold for food items or prepared meals, we can confidently say this: sodium limits on food items should be reduced to help Americans meet daily sodium goals. And the forthcoming —currently being drafted by the FDA to help Americans meet sodium targets within 10 years—should inform these reductions with evidence-based recommendations.
Current science suggests the FDA reconsider limits on total fat
As a nation, we are slowly coming to our senses after a decades-long low-fat frenzy, as science has given us a much greater understanding of the role fat actually plays in chronic disease. We now know that the type of fat we eat may influence our health more than the amount. Research consistently shows that replacing saturated fats with unsaturated fats in the diet leads to lower total cholesterol (particularly the LDL, or “bad” variety) in the blood. The existing FDA definition of “healthy” limits total fat content but doesn’t distinguish between types—meaning heart-healthy foods like almonds don’t make the cut. To address this, we propose that foods with fat content higher than current allowable levels may still bear a “healthy” label if the majority of the fat is poly- or monounsaturated. (The catch? The fats need to come from one of the health-promoting food groups named above. Adding canola oil to cookies doesn’t count.)
Food labels are important, but they aren’t enough
With this rulemaking, the FDA has an opportunity to bring its “healthy” claim into better alignment with the latest scientific findings about health-promoting foods. But there are limitations to what even the best food label can achieve. Consumers may interpret the claim in different ways, or may find themselves more influenced by price or package design. Even in the best of circumstances, a nutrient content claim generally conveys information about a given food, but it doesn’t provide the context of a balanced and healthy diet.
That’s why public investment in nutrition programs—like the Supplemental Nutrition Assistance Program (SNAP), National School Lunch Program (NSLP), and Food Insecurity Nutrition Incentive (FINI) grant program—is so important when it comes to changing the tide of Americans’ diets and our nation’s health. As the FDA begins to build their definition of “healthy,” we continue our work in defending these programs in the federal budget and upcoming farm bill to ensure that, for all Americans, “healthy” can be a reality.
Support from UCS members make work like this possible. Will you join us? Help UCS advance independent science for a healthy environment and a safer world.