Choosing a New Basis for Nutrition Labeling

One goal of the Nutrition Labeling and Education Act is to convey to consumers nutrition information they can readily understand and apply to their total daily diet. The Daily Values (DVs) and %DVs used in nutrition labeling were created to fulfill this purpose. However, they need to be updated, since they are based on the 1968 Recommended Dietary Allowances (RDAs), the 1989 Diet and Health Report, and other dated dietary recommendations.

The DVs consist of Daily Reference Values (DRVs) and Reference Daily Intakes (RDIs) and are targeted for individuals 4 years of age and older.

In 2001, the Food and Drug Administration, the U.S. Dept. of Agriculture, and Health Canada commissioned the Institute of Medicine’s Food and Nutrition Board (FNB) to provide guidance in setting values based on the Dietary Reference Intakes (DRIs) for use in food labeling.

In 2003, FNB published its report, Dietary Reference Intakes: Guiding Principles for Nutrition Labeling and Fortification. Principles 2 and 3 differ from those recommended in FNB’s 2000 report, Dietary Reference Intakes: Applications in Dietary Planning.

The 2003 report recommended that the DVs be based on a population-weighted reference value, specifically a population-weighted Estimated Average Requirement (EAR) or a population-weighted Adequate Intake (AI) for those nutrients without an EAR. The EAR by definition meets the requirements of only 50% of the healthy individuals in a particular life stage and gender group and is intended to be used for dietary planning for populations. The 2000 report, on the other hand, recommended that the RDAs be used for dietary planning for individuals. The RDAs, by definition, meet the needs of 97–98% of the healthy population—a population-coverage approach. The DRIs by definition represent a comprehensive set of reference values for nutrient intakes for healthy U.S. and Canadian individuals and populations. These reference values include the RDA, EAR, AI, and the Tolerable Upper Level (UL). The earlier FNB report set only one value, the RDA. The reports, then, recommend using different reference values as the foundation for the DVs: the EARs vs the RDAs.

The following should be considered when choosing to use a population-weighted average requirement (EAR) vs a population-coverage requirement (RDA) for the DVs:

• Nutrient Adequacy. More than 15 nutrient values could be lowered, such as iron, folic acid, and zinc. If a label says 100% of the DV, can consumers be confident that they are meeting their nutrient needs? Are major segments of the population protected?

• Consistency with Other Government Public Policy Documents. The food label implements the 2005 Dietary Guidelines for Americans and links to USDA’s Food Guidance System, MyPyramid, the dietary calculations for which are based on current FNB RDA values. The Dietary Guidelines for Americans mentions nutrients of concern for the U.S. population, including calcium, potassium, fiber, magnesium, and vitamins E, A, and C. These recommendations are also based on current FNB RDA values.

• Safety. A new DV should not exceed the UL for children 4–8 years old.

• Basis for Health and Nutrient Content Claims Regulations. The nutrient amount a food must contain to qualify for a nutrient content claim or a health claim is based on a percentage of the DV; e.g., to carry an "excellent source" claim, a food must contain >20% of the DV. Unless the regulations change, the absolute amount necessary to qualify for these claims would be likely to change, e.g., be lower. The opportunity to revise the DVs also may lead to a reconsideration of the nutrients that are required to be labeled, and could result in other nutrients, such as potassium, being required.

Perhaps the best approach is to examine each nutrient and compare the dietary adequacy and health benefit/risk of a population-weighted EAR, a population-weighted RDA, a population-weighted AI, the highest RDA, and the UL for children.

FDA has reviewed the FNB reports and plans to release an Advanced Notice of Proposed Rulemaking (ANPRM), which will include questions the agency would like answered by the public about the values used for food labeling.

Comments will be collected (usually for 90 days), then reviewed before a proposed rule is published. Once the proposed rule is published, comments will be collected (usually for 90 days) and reviewed by FDA (and most likely USDA) before a final rule is published, perhaps in 2010. The effective/uniform compliance date would be about two years later.

Further information about the ANPRM will be available on FDA’s Web site, www.fda.gov. By being aware of the process and contributing comments, we can affect the outcome.

by Constance J. Geiger,
Ph.D, R.D., a Member of IFT, Chair of IFT’s Nutrition Div., and Research Associate Professor, Div. of Foods and Nutrition, University of Utah, is President, Geiger & Associates, 3698 Gilroy Rd., Salt Lake City UT 84109,
([email protected]).

This article is based on the Daily Values session at the 2006 IFT Annual Meeting + Food Expo^®, Orlando, Fla., June 24-28.