Should nutritional labeling use the Recommended Dietary Allowances (RDA) or the Estimated Average Requirement (EAR) to communicate nutrient information to consumers? Before I weigh in, let’s take a brief history lesson on the subject.
In 1994, the Food and Nutrition Board (FNB) of the Institute of Medicine (IOM), The National Academies of Science initiated the expansion of the Recommended Dietary Allowances (RDA) to include other reference values. Since 1997, the FNB has established multiple dietary reference intakes (DRI) values that include not only recommended intakes but also additional reference intake values for both the United States (U.S.) and Canada. Two of these DRI values, the Estimated Average Requirement (EAR) and Recommended Dietary Allowance (RDA), have been the center of discussion amongst scientists and stakeholder groups, whom have debated which value is most appropriate to serve as the basis for nutritional labeling.
Currently, the U.S. standards are based primarily on the 1968 RDA values, whereas Canadian standards are based on the 1983 Recommended Nutrient Intakes. In 2002, the U.S. Food and Drug Administration (FDA) and Health Canada requested specific guidance from the FNB on how to appropriately use DRIs in nutrition labeling. Following the request of these regulatory bodies, the FNB Committee on Dietary Reference Intakes in Nutrition Labeling issued a report concluding that a population-weighted EAR should be used as the basis for nutritional labeling in the U.S. and Canada, as opposed to the traditional population-coverage RDA. The FDA issued an Advanced Notice of Proposed Rulemaking (Docket No. 2006N-0168) in 2006, proposing the recommendations of the FNB. This docket received nearly 800 sets of comments from stakeholders. By the time this article goes to press, the FDA might already have opened the docket with a notice of proposed rulemaking on the issue.
The RDA has a 97.5% probability of adequacy and is designed to be a target nutrient intake for individuals (EAR has only a 50% probability of adequacy). The RDA has a potential benefit (higher prevalence of adequate intakes) as opposed to the potential risk that a population-average EAR poses (higher prevalence of inadequate intakes), and thus is the most appropriate value to cover the majority of the population. If the percent Daily Value (DV) on nutrition and supplement facts labels are based on the highest or “population-coverage” RDA, a food with 100% DV of a nutrient will meet 97.5% of the population’s needs. From a guidance perspective, a population-average EAR is never an appropriate intake goal because, presumably, 50% of the population has intake needs that exceed this value. Also, the use of a population-coverage RDA as the basis for nutritional labeling ensures consistency with other types of guidance such as the Dietary Guidelines for Americans.
Use of a population-average EAR could lead to de-fortification of many foods as several companies may reduce the level of nutrients in their products (most companies will not create formulations with greater than 100% of the DV for any given nutrient). Bailey et al. (2011) showed that fortified/enriched foods and dietary supplements contribute to a large portion of vitamin and mineral intakes among U.S. consumers. If manufacturers reduce levels of nutrients in foods and supplements in response to new labeling rules, intakes of these nutrients are likely to decline. Consider this: since FDA allows foods with 10% and 20% of the DV to be called a “good source” and an “excellent source” of a nutrient, respectively, a less nutritious food may suddenly be able to make a label claim, unless these definitions were also revised.
Dietitians overwhelmingly agree. In fact, 69.8% of dietitians who completed a survey (n = 5,532) administered to members of the American Dietetic Assoc. (ADA) said that the RDA should be used to establish the DV, while only 8.8% indicated that the EAR should be used; the majority stating they believed it was in the interest of consumers to use the higher amount (ADA, 2008). Dietitians also agree that the nutrition facts label should mimic the supplement facts label in requiring that both absolute numbers and percentages should be provided for consistency of nutrition information. Using both of these approaches along with a population-coverage RDA enables consumers and healthcare practitioners to obtain adequate information in making informed decisions.
Consumers are likely to expect that a product (or diet) with 100% DV has a high probability of nutrient adequacy, not a 50% probability of adequacy. The DV should be based on the population-coverage RDA derived from the highest value for age and gender groups 4 years and older (excluding pregnant and lactating women).
Taylor C. Wallace, Ph.D., FACN, a member of IFT, is Senior Director, Scientific & Regulatory Affairs, Council for Responsible Nutrition, Washington, DC 20036 ( [email protected] ).
Fulgoni, V.L., Keast, D.R., Bailey, R.L., and Dwyer J. 2011. Foods, Fortificants, and Supplements: Where Do Americans Get Their Nutrients? J. Nutr. 141(10): 1847-1854.
American Dietetic Association. 2008. [Docket No. 2006N-0168] Food Labeling: Revision of Reference Values and Mandatory Nutrients; Advance Notice of Proposed Rulemaking 72 FR 62149. Comments accessed on November 17, 2011, at http://www.regulations.gov/
Taylor C. Wallace, Ph.D., FACN, a member of IFT, is Senior Director, Scientific & Regulatory Affairs, Council for Responsible Nutrition, Washington, DC 20036 ([email protected]).