for Americans and the development of an approach to evaluating added sugars content. The 2010 Dietary Guidelines for Americans, which is the federal government’s nutrition policy document, strongly recommends reducing intakes of calories from added sugars and consumption of foods containing added sugars. These products contribute to energy intake; generally contain no or low amounts of saturated and trans fats and sodium; and provide little or no essential nutrients unless fortified, which is not consistent with Food and Drug Administration (FDA) fortification policy.¹ A relatively small number of food and beverage categories contribute more than half the added sugars in the American diet.

The committee developed an approach to evaluating added sugars based on products categorized as Sugars, Sweets, and Beverages in the U.S. Department of Agriculture (USDA) Food and Nutrient Database for Dietary Studies that addresses previous concerns about analyzing foods for added sugars content. Simply stated, any product that is categorized as Sugars, Sweets, and Beverages in the USDA Food and Nutrient Database for Dietary Studies and contains added sugars would not be eligible to earn FOP points. As a consequence, major contributors of added sugars to diets, such as beverages, sugars, and sweets, would erroneously appear as being healthy because they are low in saturated and trans fats and sodium.

The strong recommendation from the 2010 Dietary Guidelines for Americans, along with the development of this approach to evaluating added sugars, led the committee to conclude that added sugars are an important component that should be included in a FOP nutrition rating system. This conclusion is consistent with the principle that an FOP symbol system should not inadvertently promote products that are inconsistent with current federal dietary guidance.

Among consumers with low literacy skills, the evidence reviewed indicates that a simple rating system diminishes the differences in choosing the healthier product between high- and low-literacy adults. FOP labeling, especially using a simple symbol, might serve as a cue or signal for consumers, helping them distinguish between products of greater and lesser nutritional quality. These findings indicate that using simple symbols to summarize complex information about product quality may be especially valuable to low-literacy populations. From its review of existing FOP systems, the committee identified four attributes that are common to most successful FOP systems:

1.  simple, understanding does not require specific or sophisticated nutritional knowledge;

2.  interpretive, nutrition information is provided as guidance rather than as specific facts;

3.  ordinal, nutritional guidance is offered through a scaled or ranked approach; and

4.  supported by communication with readily remembered names or identifiable symbols.

In considering its task to evaluate the potential benefits of a single, standardized front-label food guidance system regulated by FDA, the committee recognized that it was not constituted to evaluate regulatory or related considerations involving universal implementation of a single, standardized system. Furthermore, the committee recognized that it did not have the expertise to consider possible First Amendment issues that could arise as such a system was developed and implemented as described below. However, because the evidence showed that there are no flawless FOP symbol systems in the marketplace, the committee concluded that a single, standardized system that is easily understood by most age groups and appears on all products would be the best option for encouraging consumers to make healthier food choice and purchase decisions.

The committee determined that a single, standardized system for all foods would provide the following specific benefits:

•   Prominently provide in one symbol system information about calorie content and serving size and targeted information related to nutrients and most foods with added sugars that are strongly associated with public health concerns for Americans;

•   Facilitate comparisons of nutritional value within as well as across food categories; and

•   Encourage product reformulation.