Helping the FDA Define "Healthy" Food Labels

March 16, 2017
Photo: Marco Verch/BY-SA (Flickr)
Sarah Reinhardt
Senior Analyst, Food Systems and Health

As a registered dietitian, my perspective on healthy foods is pretty simple: there aren’t any.

Before you write to my accrediting board, let me explain. What I mean is that the extent to which a food can promote health is largely dependent on the role it plays in a person’s total diet. Are there health benefits to be gained from eating a side of salmon with dinner? Absolutely. But if I ate nothing but sockeye for breakfast, lunch, and dinner, I’d be getting only a fraction of the nutrients my body needs.

It’s a different way to talk about healthy eating, I know, and you’ll catch me departing from this dogma from time to time. But I do try to encourage people to focus on healthy diets—those containing a variety of foods (most of which are minimally processed, or would be somewhat recognizable in nature) in portions that satisfy their hunger and in forms that they enjoy.  This is part of the reason I became a public health dietitian: I think it’s important to talk about food as more than the sum of its nutrients. This pertains not only to conversations about how we consume food, but also about how we grow it, distribute it, and provide (or restrict) access to it.

Needless to say, when the Food and Drug Administration (FDA) brought health professionals, industry representatives, agencies, and advocates together last Thursday to help define the term “healthy” for food labels, I knew we were in for a challenge. Personal philosophy aside, the regulation of foods is an extremely complex task.

A little bit of background: the FDA issued a request for comments in September 2016, following a citizen petition submitted by the makers of KIND bars calling for science-based changes to the nutrient content claim “healthy.” A focal point of the KIND petition is the inconsistency between dietary recommendations, which encourage the consumption of foods like nuts and legumes, and FDA restrictions on total fat content barring these same foods from bearing the “healthy” label. (Current nutritional science tells us that quality is more important than quantity when it comes to dietary fat.)

While high-fat, health-promoting foods like nuts, salmon, and avocados enjoyed a spotlight at the public meeting, there were no shortage of questions in the room. For example, should “healthy” items be determined by food components, nutrient levels, or both? In what amounts? Would nutrients added to fortified foods count? What about phytonutrients, like the beta-carotene found in carrots or the lycopene in tomatoes?

Although the discussion is far from over, there seems to be general consensus around several points. First and foremost, the current definition of “healthy” is based on outdated science and is due for an upgrade. Second, new criteria for use of the term “healthy” on food labels should take both foods and nutrients into account. And third, the new criteria should align as closely as possible with the messages and recommendations contained in the 2015-2020 Dietary Guidelines.

The public comment period remains open until April 26, at which point the FDA will take time to review and respond to comments before publishing a proposed rule. Two issues we’ll have our eyes on include the thresholds that the FDA might identify for allowable levels of both sodium and added sugar. (The current definition of “healthy” sets moderate limits on the former and is silent on the latter.) These nutrients are of particular interest because, while most health professionals and researchers can agree that we’re consuming too much of them, we haven’t quite reached a consensus on what the limits should look like for a given snack food or prepared dish.

For our take on what should be included in the new regulations, including food-based criteria, allowable total fat distributions, and added sugar limits, read the transcript of our oral comment below. I’ll be following up with additional information and commentary as the public comment period draws to a close – stay tuned.

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UCS Comments at FDA Public Meeting on the Use of the Term “Healthy” in the Labeling of Human Food

Thursday, March 9, 2017

Good afternoon,

My name is Sarah Reinhardt. I am a registered dietitian, and am pleased to present this comment on behalf of the Union of Concerned Scientists in Washington, DC.

The 2015-2020 Dietary Guidelines for Americans emphasize the importance of choosing a variety of minimally processed, nutrient dense foods as part of a healthy eating pattern. The definition of nutrient dense foods provided by the guidelines reflects current scientific evidence on the health benefits associated with consumption of foods from key food groups, as well as the chronic disease risks associated with consumption of target nutrients. This definition provides the basis for our recommendations on the use of the term “healthy” in the labeling of human food.

UCS proposes the following modifications to the criteria required to bear the “healthy” label:

First, the term “healthy” should be characterized on the basis of foods, not just nutrients.

Health-promoting foods are those recommended by the dietary guidelines as part of a healthy diet, and include vegetables, fruits, whole grains, seafood, eggs, beans and peas, nuts and seeds, dairy products, and meats and poultry. Foods from one or more of the aforementioned groups should constitute a substantial proportion of a food item to meet standards for use of the term “healthy.” Some foods may be subject to exception from general “healthy” labels due to evidence of health risks associated with excess intake, including fruit juices, processed meat, and red meat.

Second, conditions related to total fat, cholesterol, added sugar, and sodium should be evaluated with respect to current scientific evidence.

Conditions on total fat content should be revised to provide exception to health-promoting foods with favorable total fat distributions of predominantly mono- and/or polyunsaturated fats. This reflects current scientific evidence on the health benefits of replacing saturated fats with unsaturated fats, including reduced blood levels of total cholesterol, reduced low-density lipoprotein cholesterol, and reduced risk of cardiovascular events and related deaths.

In light of advancements in the understanding of the role of dietary cholesterol in chronic disease risk, conditions related to cholesterol should be removed. This is consistent with the 2015-2020 Dietary Guidelines and reflects current nutritional science.

It is critical that updated criteria establish limits on added sugar content. Research shows that over 70 percent of the population consumes this nutrient in excess, increasing the risk of obesity, type 2 diabetes, and some types of cancer in adults. Limits should be established to help Americans limit added sugar intake to less than ten percent of daily calorie intake, as recommended by the dietary guidelines.

Lastly, allowable sodium levels should be further reduced to help protect against chronic disease.

Americans consume approximately 3,440 mg of sodium per day, 75 percent of which comes from processed foods. Foods labeled as “healthy” should contain levels of sodium to help meet daily sodium recommendations of 2,300 mg and reduce risks of high blood pressure, heart disease, and stroke.

In conclusion, it is the recommendation of UCS that the conditions required for food items to bear the “healthy” label should closely align with the definition of “nutrient dense foods” provided by the 2015-2020 Dietary Guidelines. Restructuring these criteria in a way that promotes healthy foods and restricts target nutrients will result in an established definition of “healthy” that provides clear and consistent messaging to consumers and follows evidence-based recommendations to reduce population risk of diet-related chronic disease. Thank you.