Last fall, the U.S. Food and Drug Administration (FDA) proposed an update to the nutrient content claim “healthy.” With the current definition based on nutrition science and federal dietary guidelines from nearly 30 years ago, a refresh has been long overdue. Under the FDA’s new proposal, products including the healthy claim must contain a minimum amount of fruits, vegetables, grains, proteins, or dairy while limiting individual nutrients like saturated fat, cholesterol, and sodium, as well as added sugars. The healthy designation will be used on food package labeling to steer consumers toward more nutritious choices at a glance.
The FDA’s proposed changes attempt to merge the USDA’s Dietary Guidelines for Americans and the Nutrition Facts label into a healthy claim. These efforts are a step in the right direction, as the revised healthy claim is intended to better align with updated dietary guidance. However, the move comes with potential challenges, as the proposed definition represents a major shift away from focusing on nutrients to focusing on food groups. To highlight some of the sticking points in this paradigm shift, IFT submitted the following recommendations to the FDA:
Educate consumers on how “healthy” foods fit into a healthy dietary pattern.
While the proposed rule requires minimum food group equivalents (FGEs) of fruits, vegetables, dairy, protein foods, or grains, it does not include insights on how many servings or FGEs need to be incorporated into a daily pattern, nor does it include a mention of staying within caloric requirements, both of which are key recommendations of the Dietary Guidelines for Americans (DGA).
Without additional context, consumers may not understand how foods with a healthy claim fit into an overall healthy dietary pattern, so it is important to consider the amount and frequency of consumption of foods, even those labeled as healthy in the context of overall eating patterns.
Emphasize the importance of adequate nutrient intake.
With the shift toward emphasizing food groups, nutrients of concern cannot be neglected. Nutrients like dietary fiber, calcium, iron, potassium, and vitamin D play an important role in health and are often under-consumed.
Consumers have an expectation that foods labeled as “healthy” will provide a good source of nutrients as seen in the 2022 IFIC Food and Health Survey. This is especially true for foods with a food group equivalent of vegetables, fruits, or protein. To meet consumer expectations, the FDA should consider the inclusion of beneficial nutrients in the proposed criteria for healthy to help consumers achieve nutrient adequacy in addition to food group requirements.
Gradual changes may promote consumer acceptance.
Significant changes may cause consumers to reject the new recipes for healthy products. This is especially true for sodium, which is nearly reduced by half with the proposed rule. This change will lead to significant taste differences in many products. The FDA should consider a phased reduction, which aligns with the agency’s approach for voluntary sodium reduction. The FDA should then closely monitor consumer acceptance of reformulated foods.
Avoid consumer confusion around calorie-free beverages.
To avoid consumer confusion and to ensure alignment with the DGA, the FDA should consider either not including the healthy label on any calorie-free beverage—as they do not provide nutrients of a food group—or allow all calorie-free beverages to carry a healthy claim.
Including only plain water or carbonated water under healthy calorie-free beverages excludes other beverages such as coffee, tea, flavored waters, and diet sodas that could meet the DGA’s recommendation in this category. By only including a healthy label on water, consumers will likely infer that other calorie-free beverages with flavors, colors, and no-calorie sweeteners are not healthy, which is not supported by scientific evidence.
While it is challenging to modernize the definition of healthy, doing so is a much-needed and positive step forward. Any changes to claim definitions will have both positive and negative outcomes. Thus, with any final updated definition of healthy, it will be essential to monitor, track, and adjust to ensure the best possible results for consumers.
Read IFT’s full list of recommendations to the FDA on its proposed healthy rule.
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A conversation with IFT's senior food safety and traceability scientist Sara Bratager