National Academies Press: OpenBook
« Previous: Front Matter
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 1
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 2
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 3
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 4
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 5
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 6
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 7
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 8
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 9
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 10
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 11
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 12
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 13
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 14
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 15
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 16
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 17
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 18
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 19
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 20
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 21
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 22
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 23
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 24
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 25
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 26
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 27
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 28
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 29
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 30
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 31
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 32
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 33
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 34
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 35
Suggested Citation:"1. Summary." Institute of Medicine. 1990. Nutrition Labeling: Issues and Directions for the 1990s. Washington, DC: The National Academies Press. doi: 10.17226/1576.
×
Page 36

Below is the uncorrected machine-read text of this chapter, intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text of each book. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

1 Summary In 1973 the Food and Drug Administration (ADA) took the first steps to establish the current U.S. framework for the nutrition labeling of foods. For most packaged foods, FDA's regulations allowed information on nutrition content to be provided voluntarily, but prescribed a standard format. Nutrition labeling was made mandatory, however, on any food to which a nutrient was added or for which a nutrition claim was made. Not long afterward, the U.S. Department of Agriculture's (USDA) Food Safety and Inspection Service (FSIS) issued similar policy guidance for nutrition labeling on meat and poultry products. By 1990, over half of all packaged foods sold in the United States bore some type of nutrition labeling. The changes in food labels begun in the 1970s then represented a fundamental shift in regulatory philosophy and a major advance in consumer information, but from the perspective of 1990, they seem modest, incomplete, and outdated. Criticism of the nutrition content of food labels grew intense in the 1980s. This criticism was spurred by two related developments. First, scientific in- vestigation had convincingly demonstrated important linkages between dietary habits and the prevalence of chronic diseases, most notably cardiovascular dis- ease, cancer, stroke, diabetes, and obesity. And at the same time, it was shown that Americans' diets were excessively abundant in such components as calo- ries, fat, cholesterol, and sodium. The second development was a response to the first: American consumers became increasingly attentive to choices among foods. Food producers and manufacturers responded to this interest by develop- ing foods whose composition could be promoted as reflecting this new learning about nutrition and health. Thus, in the late 1980s the expanding use of the cur-

2 NUTRITION LABELING rent nutrition labeling system further highlighted its inadequacies. The release of two landmark reports, The Surgeon General's Report on Nutrition and Health and the National Research Council (NRC) report, Diet and Health: Implications for Reducing Chronic Disease Risk, led to renewed efforts to reform nutrition labeling in the United States. In 1990, the rules governing food labeling are seriously dated Some foods subject to FDA food standards remain exempt from full ingredient labeling. No nutrition information appears on at least 40 percent of all packaged foods; nor does it accompany major segments of the food supply, including fruits, vegetables, meats, poultry, seafood, and restaurant meals. Furthermore, the information that nutrition labeling does provide is incomplete and misfocused. The current system emphasizes the presence and levels of micronutrients, disclosure of fiber and cholesterol contents is not required, and information about fat is incomplete. In addition, advertising and label claims of nutritional value or disease avoidance have proliferated-with seemingly little control. It is, therefore, understandable that critics of the current system have charged that government regulation has ignored major segments of the food supply, been concerned with the wrong nutrients, and tolerated nutrition claims in advertising and labeling that are at best confusing and at worst deceptive economically and potentially harmful. There have been earlier efforts to reform the current rules for nutrition la- beling. In 1979, the U.S. Department of Health, Education, and Welfare, USDA, and the Federal Trade Commission ~C) held hearings and considered possible changes in many areas of food labeling (44 Fed. Reg. 75,990 76,020, Dec. 31, 1979~. In the past 12 years, members of the U.S. Congress have introduced legislation to overhaul FDA's and USDA's nutrition labeling regulations. Many private organizations have also put forth proposals for improved food labels generally and their nutrition content in particular. PURPOSE AND SCOPE OF THE STUDY In 1989 the Committee on the Nutrition Components of Food Labeling was assembled by the Food and Nutrition Board (FNB) of the Institute of Medicine to consider how food labels could be improved to help consumers adopt or adhere to healthy diets. The sponsors of the study the Public Health Service, U.S. Department of Health and Human Services (DHHS), which includes FDA, and FSIS, USDA were motivated by the shared judgment that changes in eating habits can improve the health of Americans and a conviction that food labeling can materially aid wise dietary choices. The Committee was charged with addressing the following tasks: assessing the implications of the current knowledge of nutrition and health for food labeling; recommending the content and the appropriate format for food labels, taking into account the scientific data base as well as the means to communicate

SUMMARY 3 effectively with the public and, after examining current laws and regulations governing ingredient and nutrition labeling, proposing options for modifying current policy. The Committee was directed to use the findings of He Surgeon General's and N}<C reports as the scientific basis for proposed labeling changes. Any system of food labeling reflects assumptions about the purposes of and audience for nutrition information. The Committee believes that nutrition labeling should provide consumers with information that they can use to make choices among and between foods based on nutritional value, prevent consumer deception by providing accurate information on the product quality, and provide manufacturers with incentives to improve food products by requiring full dis- closure of the ingredients and nutrient values of their products. The Committee believes that food labels must be easy to lead, understandable, informative, non- deceptive, consistent across and among products, and uniform nationwide. Many consumers already use nutrition labeling, including the millions of Americans with special dietary requirements due to underlying health conditions and He many other healthy consumers who are interested in improved diets. A much larger potential audience consists of consumers who do not now use labels and who will need education before they can use labels effectively. The Committee focused chiefly on the labels of packaged foods. However, many foods are sold without conventional labels, and some with labels are sold in conjunction with additional graphic or textual material. The Committee, therefore, considered point-of-purchase as well as conventional labels in its as- sessment of ways to convey nutrition information to consumers. The Committee was aware of the public interest in nutrition messages about foods conveyed in advertising. The proliferation of health claims for food products is largely a re- sponse to the scientific findings about the relationship between diet and chronic disease that precipitated the current interest in nu~idon labeling reform. Since the Committee was not asked to evaluate food advertising and health claims, generally, it confined its consideration of claims to "nutrient content descriptors" on food labels and in labeling. In addition, the Committee generally did not deal with issues concerning food labels and their reform that did not have an obvious berg on the nutritional quality of food, i.e., food safeW concerns. OVERVIEW OF THE U.S. SYSTEM FOR REGULATING FOOD LABELING The U.S. government operates two systems for regulating food labels in- volving two federal agencies- USDA and FDA. Through FSIS, USDA regulates the labeling of meat and poultry products under the authority of He Federal Meat Inspection Act (FMI Act) and the Poultry Products Inspection Act (PPI Act). Operating under the Federal Food, Drug, and Cosmetic Act (FD&C Act), FDA regulates labeling of all other foods. None of these laws provide any guidance

4 N=RTTION LABELING as to the information about nutrient content that must or may appear on food labels; the current rules reflect the informal judgments of FDA and USDA. USDA and FDA regulate food labels in very different ways. USDA requires that manufacturers obtain prior approval of any label they wish to use on a meat or poultry product. USDA labeling policies are spelled out In the FSIS Standards and Labeling Policy Book and policy memoranda In theory, no USDA-regulated products fail to comply, because USDA reviewers simply withhold label approval. FDA has no legal authority to approve food labels in advance. It relies on detailed formal regulations and informal advice to describe its requirements. Manufacturers of FDA-regulated foods can use a new label and take the risk Hat FDA will subsequently challenge its product as being mislabeled. As a result, compliance with FDA policies depends on attentive monitoring and is resource dependent. Although the substantive requirements of the two agencies do not differ dramatically in the area of nutrition, they do differ in some details. Moreover, there can be uncertainty as to which agency's requirements apply to a particular food. For example, the amount of meat in a pizza determines which agency has jurisdiction. A modest change in product composition can result in a change in jurisdiction. Evolution of Nutrition Labeling of Foods FDA's nutrition labeling regulations have undergone relatively few changes since 1973. These regulations derive their authority from the FD&C Act, which states nothing about nutrition. The Act requires that every food label must contain the name of the food, a statement of net quantity of contents, and Be name and address of the manufacturer or distributor. In addition, most FDA- regulated foods must also list ingredients in descending order by weight. The Act also prohibits label statements mat are false or misleading. A unique provision of the Act (section 201(n)) specifies that, in determining whether the labeling of a food is misleading, consideration should be given to whether it fails to reveal material facts about the consequences of using the product. This provision, and FDA's general power to adopt regulations to enforce the Act, formed the basis for the agency's 1973 nutrition labeling rules on packaged food labels. It was the 1969 White House Conference on Food, Nutrition, and Health, convened to respond to reports of widespread malnutrition in America, that motivated FDA's initiative. The final report of the conference addressed the regulation of food composition and labeling, criticizing FDA's approaches to standards of identity, marketing of substitute foods, and label statements relating to nutrition and long-term health. The report stressed the need to help consumers make wise food choices by providing more nutrition information on food labels.

SUMMARY s In response to the report, FDA initiated the adoption of regulations govern- ing voluntary nutrition labeling for packaged foods. The regulations specified how nutrition information was to be provided if manufacturers chose to include it, and prescribed that nutrition labeling was required when a nutrient was added or a nutrition claim was made. In 1973, the goal was to enable consumers to select a diet adequate in vitamins, minerals, and protein. Thus, labels were re- quired to provide information on the food's contribution to the desired daily consumption of these nutrients. To convey this information FDA cleat the U.S. Recommended Daily Allowances (U.S. RDA), which were based on the Recommended Dietary Allowances (RDA) established by FOB but reduced them to a single set of numbers applicable to healthy adults. FDA's 1973 regulations prescribed a uniform sequence and format for dis- closure of nutrition information in terms of serving size; servings per container; number of calories; amount of protein, carbohydrate, and fat (in grams per serving); and percentage of the U.S. RDA for protein, Titanic A, vitamin C, thiamin, riboflavin, niacin, calcium, and iron. A manufacturer also could list a number of other vitamins and minerals. A separate regulation allowed, but did not require, disclosure of fatty acid composition and cholesterol information, but only with an accompanying statement that such information was provided to assist individuals who were under the care of a physician. Information on the label about sodium content was required in 1984. To convey nutrition information, FDA chose a numeric format over other alternatives. This choice seems to have been based more on informed intuition than on extensive testing of utility. FDA's scheme effectively limited the cov- erage of nutrition labeling. It did not have authority to require labeling on most meat and poultry products. Foods sold in restaurants and other food service operations were excluded. The agency's original plan to require nutrition label- ing for fruits and vegetables, albeit with modified conditions, was withdrawn in 1975. Although USDA has never adopted formal regulations governing nutrition labeling of meat and poultry products, it has evolved policies for such labeling that paralleled those of FDA. They are found in the FSIS Standards and Labeling Policy Book and policy memoranda. Policy Memorandum 039 allows a product's label to state that the food can help reduce or maintain body weight or to make a claim regarding caloric content as long as it provides nutrition information. Policy Memorandum 086, which sets forth USDA's required format for declaring nutrition information, allows either an abbreviated listing (calories, protein, carbohydrate, and fat [in grams] per serving) or the longer FDA version. USDA has also allowed provision of information about cholesterol and fatty acid content as part of either format. The more significant differences between the two agencies concern the philosophy and manner of implementation. FDA has typically encouraged manufacturers to provide information even when it is not required, whereas

6 Nl~RITlON L4BEl~NG USDA has been chiefly concerned with ensuring the accuracy of whatever information appears on meat and poultry products. Deficiencies in Current Federal Requirements for Nutrition Labeling Critics of current nutrition labeling cite its limited coverage, the failure to keep pace with current knowledge of the relationship between nutrition and long-term health, the amassing of information about fats and fiber, incomplete information about ingredients, misleading or undefined statements about the levels of nutrients, lack of uniformity, and inadequate consumer education efforts. Currently, only over half of packaged foods carry nutrition information. Other foods omitted from nutrition labeling include meat, poultry, and seafood; eggs; fruits and vegetables; and foods sold in restaurants, institutional food services, vending machines, and grocery store carryout food bars. In addition, some foods subject to FDA's standards of identity (official recipes used to define the composition of standard products) still fail to list all their ingredients. The content of current nutrition labels is incomplete given current knowl- edge of the relationship between diet and chronic disease. Labels are not now required to list cholesterol, saturated, monounsatu~a0, or polyunsaturated fatty acids, complex or simple carbohydrates, dietary fiber, and potassium, for whose inclusion there is some support. Many observers believe that labels list too many vitamins and minerals. It is not only the nutrition information on food labels that has been criticized. Listing of ingredients by percentage has been urged. Current provision for"and/or" ingredient labeling allows manufacturers to declare a number of ingredients without specifying which ones are actually present in foods. In the case of fats and oils, it is difficult for consumers to determine the level of saturated fat in specific foods. Sugars are not currently required to be aggregated in the ingredient listing. Confusion is reported about the meaning of both serving size and the U.S. RDAs. Nutrition information is provided as the amount per serving, but manufacturers determine the serving size, which has allowed manipulation. Serving sizes are not uniform within or between product categories. In addition, serving sizes are frequently expressed in units that consumers do not understand. The U.S. RDAs, which serve as the reference point for describing micronu~ient content, have not been updated since 1972. Finally, EDA's original choice of a numeric display rather than narrative, graphic, or symbolic presentation of nutrient information remains controversial. Some groups suggest that current dietary recommendations should also be included on labels so that consumers can compare these standards with a food's nutrient composition. There is debate, as well, over how the caloric contribution

SUMMARY 7 of fat can best be shown, either by calories from fat or He percentage of calories from fat. CONTEXTUAL FACTORS INFLUENCING FOOD LABELING REFORM Current Dietary Patterns of Americans Since the turn of the century Americans have made extensive changes in their eating habits. More food is consumed away from home. Snacking is more common. A wider variety of foods is available year-round. Changes have occurred in He composition of foods due to improved production methods, new varieties of foods, and advances in food processing. Records maintained and surveys conducted by USDA and DHHS confirm these changes. The primary changes in food energy sources in the past 70 years have been an increase in the percentage of energy contributed by fats, oils, sugars, and sweeteners, along with a decrease in the percentage of energy contributed by grain products. There has been no change in the amount of protein consumed, but the amount obtained from animal sources has risen. The consumption of fat and its components (certain fate acids and cholesterol) has increased. Consumption of whole mink products and eggs has declined, whereas consumption of fats and oils, primarily salad and cooking oils, has nsen. Current fat intakes are about 36 percent of total calories, compared with the frequent dietary recommendation of 30 percent of total calories from fat. Dietary fats are considered to be a current public health issue due to their association with coronary heart disease (CHD) and certain cancers. There has been a significant decrease in the proportion of carbohydrates obtained from grain products, with an increase in the consumption of sugars and sweeteners to 50 percent of total carbohydrate calories. No historical data exist on the amount of fiber available in the food supply, but current intakes are generally considerably less than the recommended minimum of 20 g/day. Americans generally consume an adequate amount of most vitamins and minerals due to new plant vaneties, food fortification, and supplement use. However, there is concern about general low consumption of several micronutrients, primarily calcium and iron, and in certain population groups, vitamins A and C, folate, and zinc. Food Marketing in the United States A 1990 U.S. Deparunent of Commerce document, U.S. Industrial Outlook, suggests that consumers demand foods with convenience, quality, variety, and healthful attributes. By 1990, an average of 12,000 new food products were being introduced annually in supermarkets, more than double the number a decade earlier. Many of these products are targeted directly at a health~onscious public

8 NllTRITlON LABELING and feature health and nutrition claims on their labels, and more advertising dollars are being allotted to their promotion. Sales of foods in limited-menu restaurants and foods for home use purchased in supermarkets have risen sharply, whereas those from limited-line grocery stores have fallen. The increasing integration of the food distribution system with trade throughout the world will continue to affect the U.S. food supply. Current Coder Alimentarius rules and the scheduled 1992 adoption of food labeling rules by the 12 member nations of the European Community are all likely to have an impact on trade in the future, as well as the United States Canada Free Trade Agree- ment. In the area of food processing, growing internationalization has occurred in food company ownership, and the pace of leveraged buyouts and takeovers has reduced funds for product research and development. From a general marketing standpoint, it is readily apparent Hat nutrition "sells" food to today's consumer, and it has become an integral part of product development and marketing strategies. Manufacturers view the principal display panel of food packages as "real estate," to be reserved for sales promotion and competition with nvals, and will not willingly surrender it to government labeling requirements. Although industry can be expected to generally support labeling changes that will create a more informed consumer choice process, it will resist changes perceived to disturb consumer perception of product value, erode consumer ability to evaluate products in the context of total diet, or risk the disclosure of proprietary formulations. Consumer Understanding of Nutrition and Use of Food Labels No single study has adequately described how dietary patterns are devel- oped, maintained, and changed; food choices are influenced by social, cultural, economic, psychological, and physiological factors. Familiarity is a particularly important factor in choosing foods. Education and income levels have a signif- icant influence on food choices. Results of the 1990 Food Marketing Institute (l;MI) survey of consumer attitudes and shopping behavior indicate that over 70 percent of shoppers identified taste, nutrition, and product safety as very important factors. Those on medically restricted diets were more likely to rank nutrition first. Numerous studies have confirmed that Americans are increasingly interested in nutrition, including increasing concerns about the health risks associated with sodium, fat, and cholesterol intakes. They report eating less salt, red meat, butter, whole milk and eggs. Motivation is a key factor in how receptive any target audience will be to new information. Curiosity about a new claim may lead to a specific food purchase. Medical advice to limit certain food components often leads to closer attention to nutrition information. However, increased knowledge about nutrition

SUMMARY 9

10 NUT~lTlON LABELING Analytical Considerations Aflecting Food Labeling Reform Providing information about the nutrient content of foods on labels requires an analysis of food composition. Both FDA and USDA currently have require- ments for label accuracy that reflect the current capacity of analytical chemistry. USDA permits manufacturers to provide nutrition information derived either by calculation from analyses based on official methods of the Association of Official Analytical Chemists (AOAC) or accepted references. USDA has implemented the Nutrition Label Verification ~V) program, which includes procedures to verify labels for accuracy, although the degree of accuracy that is required im- poses analytical problems on food manufacturers. PDA regulations mandate that all the required and any optional information on the nutrition information panel must be determined by direct laboratory analysis. A + 20 percent tolerance from label values is allowed. FDA generally requires that analysis be done by AOAC- approved methods or by reliable and appropriate analytical procedures set by the Secretary of DHHS. Acquisition of reliable food composition data is not easy. Difficulties include complexities of analytical methods and food composition, differences in the analytical capabilities of different laboratories, and the need for improved analytical methods and training of technicians. Current methods vary with respect to their applicability, convenience, expense, and the degree of analytical expertise required to perform them. Considerable improvement is needed in the validation and standardization of methods of food analysis for use in labeling as well as food composition data bases. Soluble fiber cannot easily be measured, since it is usually calculated by determining the difference between total dietary fiber and insoluble dietary fiber, which is subject to considerable imprecision compared to a direct measurement. Thus, the method remains controversial. Measurement of total carbohydrate per serving for food labeling purposes is generally performed indirectly by determining the amount remaining after protein, ash, moisture, and fat are subtracted, resulting in potential inaccuracy and imprecision. Recent advances in the methods used to measure complex carbohydrates will allow for potentially more accurate measurement of various carbohydrate components. Total fat is currently measured routinely, and methods exist for the accurate measurement of cholesterol. Suitable methods exist for the measurement of most minerals in foods, although standardization and validation are needed. Considerable development is required to obtain reliable analytical methods for many vitamins in foods, because of natural variability, especially in plant sources. The application of direct analytical analyses to nonpackaged foods, includ- ing meat, poultry, seafood, fruits, and vegetables, and foods sold in restaurants, is impractical. The need to expand public access to information about the nu- trient content of foods suggests the desirability of using appropriate data base information as an alternative to direct analyses for these foods. The USDA Na-

SUMMARY 11 tional Nutrient Data Bank contains reasonably complete data on the composition of foods, although data are less complete on nutrients for which sound analyt- ical methods are lacking. Other sources of food composition data complement USDA data, but these need to be certified by FDA and USDA to be used for nutrition labeling purposes. At best, however, data bases can indicate represen- tative information on the composition of foods, which means that Here may be large differences between data base values and the actual amounts of certain nutrients in a single sample of food. The Committee recommends that: · Label verification by analysis of composite samples should be made at least twice each year to ensure reasonable accuracy of nutrition labels without imposing the burden of a complete quarterly analysis. · FDA and USDA should certify data from the National Nutrient Data Barik or other appropriate sources regarding the nutrient content of fresh foods and foods sold in restaurants. FDA and USDA should allow considerable flexibility in the selection of analytical methods for label verification of nutrient content. In proposing an alternative (nonofficial) analytical method, suitable verifi- cation must be required (e.g., recovery of samples and analysis of reference materials). In addition, appropriate quality control procedures should be used in each analysis. · Development of additional standard reference materials for use in food analysis should be encouraged. · Funding should be provided for the development of improved analytical methods, establishment of programs for the testing of methods through interlaboratory studies, and development of additional standard reference materials. · Completion and expansion of the USDA National Nutrient Data Bank should be continued. LABELING COVERAGE Mandatory Nutrition Labeling Although nutrition knowledge will continue to evolve, there is now sufficient consensus on diet and long-term health to serve as a basis for changes in food labeling. The Surgeon General's report and the NRC Diet awl Health report indicate that consumers must make changes in both the dietary components and the food groups they eat, if they are to reduce their risk of chronic disease. In order to achieve the recommended dietary adjustments, consumers must be able to make informed choices in their daily selection of foods. The current lack of relevant, consistent information across Be full spectrum of food products

12 NUTRITION L4BEl~NG is a significant deterrent to consumers who wish to make informed choices. However, certain foods need to be either exempted from these requirements or, in the case of foods for children under age 2 with special dietary requirements, have alternative labeling requirements more suitable to that group of foods. The Committee recommends that: . FDA and USDA should promptly adopt regulations to institute mandatory and uniform nutrition labeling requirements for all packaged foods within their respective jurisdictions, with limited exemptions. · Exemptions from the general requirement should only be granted in those situations in which alternatives to nutrition labeling have been fully exnloreA and determined to be unreasonable, impractical, or too costly. · Food designed for children under age 2 should be exempted from the general requirements; nutrition labeling of macronutrients in baby foods should be required, with the optional listing of all micronutrients, except for calcium and iron declaration. · Nutrition labeling should be required on institutional-size packages and commodity foods or on product specification sheets. ~ ,¢ Produce, Seafood, and Meat and Poultry Recent dietary recommendations emphasize that Americans should reduce their consumption of fat and cholesterol by eating more fruits, vegetables, seafood, poultry, and lean meat. Nutrition information on fresh foods would aid consumers in making appropriate food choices. However, providing nutrition information about fresh foods presents some special challenges. Presh foods are more heterogeneous than formulated foods, which are more uniform in composition and are batch tested. The variability of the nutrient content of fresh foods is due to factors such as biological variability, climate, seasonal variations, agricultural practices, and animal husbandry. The effects of storage and cooking on fresh foods further affects their nutrient composition. None of these factors are reflected in nutrient composition information provided in data bases. For fresh foods, the use of food composition data may provide a practical alternative to laboratory analysis. Although the USDA National Nutrient Data Bank is not totally complete, the data base provides an adequate basis for use of nutrient content information in point-of-purchase labeling of most fresh foods. An alternative data bank has been developed by the Produce Marketing Association for about 30 different produce commodities. FDA and USDA currently require that nutrient information be based on analytical data of foods as actually purchased, which effectively precludes the use on the food composition data bases. The Committee recommends that: Retailers should be required to provide point-of-purchase nutrition labeling 1

SUMMARY 13 information for produce, and for fresh and frozen meat, poultry, and seafood (e.g., 20 to 30 top items in each category using data base information, rather than lot-by-lot analysis). After the first 3 years, the program should be evaluated for consumer reaction, use, and understanding and modified accordingly. · FDA and USDA should allow flexibility in the format and the nutrition information required for labeling of fresh foods. · FDA and USDA should establish a joint committee to certify He data bases and acceptable methodologies for providing nutrient composition data for fresh foods. · EDA and USDA should continue to improve the USDA's National Nutrient Data Bank, particularly in the area of fresh foods, in harmony with the above recommendations. Foods Sold by Restaurants Americans currently spend about 43 percent of their food dollar on meals eaten away from home, which is expected to total $156.4 billion in 1990. The National Restaurant Association estimates that 45.8 million Americans (about 20 percent of the population) eat in refreshment places each day. According to a 1989 National Restaurant Association survey, an increasing number of consumers are concerned about the types of foods available in restaurants. Restaurants are paying more attention to providing foods that are consistent with current dietary recommendations. In the past 5 years, the number of restaurants reporting that they have nutrition information on their menu items available for those consumers who request it has doubled. Many restaurants have menus coded for items that are low in fat, cholesterol, salt, and calories. Some groups have urged that restaurants provide more information on the ingredients and nutrient contents of foods served to aid consumers who are concerned about their intake of salt, fat, and sugar. Although primary attention has focused on the limited-menu segment of the restaurant industry, there is no evidence to suggest that meals served in other restaurants are necessarily more nutritious or likely to meet the recent dietary recommendations. The nutrient composition of menu items can be computed either by the use of readily available computer software or by subscribing to programs that perfo~ the evaluation. Nutrient content information should be based on the standardized serving sizes for foods in limited-menu restaurants. For other restaurants, normative serving sizes will need to be identified by the agencies. Because Americans are consuming a growing number of their meals in restaurant settings where nutrition information is not routinely available, Be Committee recommends that: · All restaurants should be required to have standard menu items evaluated

14 NUTRITION LABORING for their nutritional profiles and provide this information to patrons upon request. · Restaurant menus should be required to state that '`nutrient evaluation is available upon request," so that consumers can, if they desire, obtain such information. · FDA and USDA should, through regulations, allow the use of nutrient data bases to provide nutrient evaluation of menu items. · Food senice establishments above a specified size and/or volume (lim- ited-menu and regionaVnational restaurant chains) should be required to provide nutrition analysis of food items at the point of purchase. This requirement can be met by placing the information either on package wrappers and containers or at some other point-of-purchase location that allows consumers easy access and use. · Restaurants should be encouraged to participate in programs and/or other- wise provide for appropriate symbols or descriptors on menu items that iden- ~fy foods that meet criteria for low-calorie, low-fat, low-cholesterol, and/or low-sodium. Comparable definitions for symbols and descriptors should be established by FDA and USDA. · FDA and USDA should define the categories and size of restaurant op- erations for which regulations based on the above recommendations are applicable. Foods Sold by Noncommercial Food Services In recent years, institutional food service operations have grown substan- tially as an increasing number of meals are being prepared, sewed, and con- sumed outside the home. Members of all age groups are eating away from home in institutional or congregate settings. Children may eat up to two meals per day at school. Long- and short-term health care facilities are feeding a growing population of elderly people. Military installations, correctional facilities, and institutions of higher education feed millions of people daily. None of these noncommercial services have strict rules on seeing meals that meet current di- etary recommendations. Many of their customers, however, are health conscious and/or are open to nutrition education programs. The Committee recommends that: . The agencies at the federal, state, and local levels that oversee or support noncommercial food services encourage voluntary nutrition labeling of meals at the point of purchase or point of selection as part of overall nutrition education efforts.

SUMMARY 15 NUTRITION LABEL CONTENT Current nutrition labeling contains information on calories, protein, fat, carbohydrate, sodium, and percentage of the U.S. RDA for protein and seven micronutrients. In light of recent dietary recommendations for changes in the consumption of certain dietary constituents, it is necessary to reexamine the nutrient information required on food labels and in labeling. Health Relevance of Nutrient Recommendations Calories Despite the continued controversy over the causes of obesity, consensus exists that obesity is related to morbidity and mortality from chronic diseases. Recent dietary recommendations have emphasized the importance of maintaining a desirable weight to minimize the risk of chronic disease. An estimate 34 million Americans are overweight, and more Han 80 million are trying to control their weight. In order to achieve and maintain a desirable weight, caloric intake must be in balance with energy expenditure by decreasing caloric intake and increasing energy expenditure. Calories are the one component of the food label that most consumers understand, and its presence is useful to those who are trying to attain a desirable weight and balance their consumption of macronutrients. The principal display panel of food packages may carry a statement on calories per serving and/or a descriptive term indicating that the product has fewer calories Han its counterparts in the marketplace. On the nutrition information panel, He caloric value for a single seeing of the food is expressed as the number of calories per serving. The Committee recommends that: FDA and USDA should continue to require the disclosure of calories expressed as kilocalories per seeing on the nutrition information panel. · If the manufacturer chooses to express nutrients as a percentage of total calories, 2,000 calories should be used and stated as He reference point for the average adult who engages in light physical activity. · Descriptors related to caloric content of foods that are currently defined by FDA and USDA should be continued. · FDA and USDA should define and standardize the terms light, lite, and diet and other descriptors that can be interpreted as caloric claims. Fat and Cholesterol Dietary fats and oils primarily provide energy and various other characteris- tics that relate to current health concerns. Cholesterol is another lipid component

16 NUTRITION LABEllNG related to health concerns. The health effects of dietary fat and cholesterol range from CHD to cancer and gallbladder disease, and the high caloric density of fats has an impact on caloric intake. The ingredient listing provides information on the sources of fat contained in foods. "And/or" labeling is currently allowed so that manufacturers can list several fats or oils that might be used in a product. In the absence of a claim, voluntary use of the nutrition information panel provides quantitative information on the amount of total fat (in grams) per serving. The principal display panel of food packages features descriptors used to highlight fat and cholesterol contents. Current labeling requirements for fat disclosure have several limitations. "And/or" labeling fails to reveal not only the specific fats and oils used in a particular food, but also the differences in the degree of fatty acid saturation. Unless a claim is made about the fatty acid or cholesterol contents of a food or the information is provided voluntarily, the nutrition label does not contain information on the degree of saturation of fats or the cholesterol content of a food. In addition, the lack of standardized definitions for many terms used to describe fat and cholesterol contents contributes to confusion and misrepresentation. The Committee recommends that: . FDA and USDA should require the disclosure of total fat, saturated fat, unsaturated fat, and cholesterol contents per serving in grams (milligrams for cholesterol) on the nutrition information panel, with samurai and unsaturated fat either indented or otherwise identified as subcategories of total fat. FDA and USDA should require the listing of calories per seeing from total fat, saturated fat, and unsaturated fat on the nutrition information panel. FDA and USDA should allow, as an option, the disclosure of monounsat- urated and polyunsaturated fatty acid contents per seeing in grams on the nutrition information panel. FDA and USDA should define descriptors for cholesterol content for use on the principal display panel. FDA and USDA should define descriptors for total fat and saturated, monounsaturated, polyunsaturated, and unsaturated fatty acid contents on the principal display panel. FDA and USDA should require that when a manufacturer refers to "x percent total fat" (by weight) and other similar terms on a package, it should also be required to state "x percent calories from fat" in close proximity in the same type size and type face. FDA and USDA regulations should continue to allow "and/or" labeling of fats and oils in the ingredient listing on the conditions that the food cames full nutrition labeling and that the stated saturated fat content listed is the

SUMMARY 17 highest level that would be achieved with any mixture of the listed fats and oils. · FDA and USDA should establish an entity to evaluate the issue of the cholesterolemic effects of stearic and other fatty acids (e.g., bans fatty acids) and related changes that may need to be made in redefining fatty acids for regulatory purposes. Carbohydrates Carbohydrates provide about 45 percent of total adult caloric intake, about half of which is provided by complex carbohydrates. Diets Mat exclude or are low in whole grains, fruits, and vegetables are associated with a variety of chronic health problems, including obesity, cancer, heart disease, and diabetes. The Surgeon General's and NRC's reports have recommended mat Americans should increase their consumption of complex carbohydrates. Although foods high in complex carbohydrates may not contribute directly to chronic disease prevention, these foods are usually low in fat and calories and high in fiber. Health concerns about the consumption of simple carbohydrates focus on the incidence of dental caries, nutrient dilution, and potential source of excess calories. The principal display panel of food labels may carry descriptors as well as brand names that characterize the sugar content of products but seldom provides information on carbohydrate content. In the ingredient listing, sugars are listed individually among other ingredients in the order of predominance even though Hey may collectively comprise the major component (by weight) of the product. The nutrition information panel lists total carbohydrate per serving (in grams). Some manufacturers voluntarily list complex carbohydrates and simple carbohydrates (sugars) separately, but this is not required. The Committee recommends that: FDA and USDA should continue to require the disclosure of carbohydrate content per serving in grams on the nutrition information panel. · FDA and USDA should allow as an option the listing of the content of complex carbohydrates (which are defined as digestible polysaccharides such as starch and glycogen), and sugars (which are defined as digestible mono- and disaccharides) per serving in grams on the nutrition information panel. The term total carbohydrate should be used when carbohydrate components are listed, with these subgroups indent · FDA and USDA should allow, as an option, the listing of calories per serving from total carbohydrate, complex carbohydrate, and sugars on the nutrition information panel. The ingredient listing should group all sugars together under the term sugars with mono and disaccharides (including glucose [dextrose3, fructose, lac-

18 NErrRlTIoN LABELING lose, sucrose, invert sugar, and honey, as well as corn syrup, high-fructose corn syrup, and mild flavored and "stripped" concentrated fruit juices) in a parenthetical listing, in descending order by weight under this teen. Sugar alcohols, such as mannitol and sorbitol, would be listed separately and would not be grouped with sugars. · FDA and USDA should consider allowing manufacturers to use "and/or" labeling for sugars. FDA and USDA should define descriptors that apply to terms used for carbohydrate and sugar content on foods labels. Dietary Fiber For a decade, Americans have been advised to increase their consumption of dietary fiber on the basis of suggestive evidence of a possible link with the incidence of CHD, certain cancers, and diabetes, although studies of the protective role of dietary fiber per se has been inconclusive to date. Recent research suggests that soluble fiber (e.g., that found in oat bran, beans, and certain fruits) is associated with lower blood glucose and blood lipid levels. And there is some evidence that an overall increase in intake of foods that are high in insoluble fiber might decrease the risk of colon cancer. The strongest argument for an increase in consumption of dietary fiber is the important contribution it makes to normal bowel function. FDA currently allows listing of dietary fiber on food labels, but does not require it. In addition, descriptors of fiber content are prominent on the principal display panel of some foods. The Committee recommends that: · FDA and USDA should require the disclosure of fiber content per serving in grams on the nutrition information panel under the term total dietary fiber. FDA and USDA should define He scope of foods from animal origin and other foods that contain little or no dietary fiber which should be exempted from this requirement. FDA and USDA should discourage labeling of soluble or insoluble fiber contents until methodologies approved by the agencies allow for the ad- equate and reproducible quantification of the soluble and insoluble fiber contents of a variety of foods. FDA and USDA should define descriptive terms allowed to be used for various source levels of dietary fiber on food labels.

SUMMARY Protein 19 The majority of Americans consume protein in excess of the RDA. So far there is little evidence that diets high in protein increase the risk of chronic diseases, but the hypothesis still commands continued research attention. The listing of ingredients provides information on protein sources if consumers recognize them. The nutrition information panel currently lists protein in grams per serving and as a percentage of the U.S. RDA. Protein content claims may also appear on the principal display panel. The Committee recommends that: · FDA and USDA should continue to require the disclosure of protein content per serving in grams on the nutrition information panel. However, protein should be moved to a position of less prominence. The current requirement to list protein content as a percentage of the U.S. RDA should be eliminated. · FDA and USDA should allow, as an option, the listing of total calories per serving from protein. FDA and USDA should define descriptors that apply to terms used for protein content on food labels. Sodium For years, concern about the adverse health effects of sodium has focused on the role of sodium in causing high blood pressure, heart failure, and edema Hypertension, which affects 60 million Americans, is a major risk factor for CHD, hypertensive heart disease, arteriosclerosis, stroke, and renal failure. Current intakes of sodium by the U.S. population are widely regarded as excessive. The ingredient listing provides information on salt and other sodium- containing ingredients that are added to a food. FDA's original nutrition labeling regulations did not require listing of sodium content per serving, but, effective July 1986, the agency required sodium to be listed (in milligrams) whenever nutrition labeling was provided or a claim about sodium content was made. Sodium could also be declared voluntarily without triggering full nutrition labeling. These regulations also defined several descriptive terms for sodium content: sodium free, low sodium, reduced sodium, unsalted, and no added salt. USDA has adopted essentially identical guidelines. The Committee recommends that: · FDA and USDA should continue to require the disclosure of sodium content per serving in milligrams, regardless of source (whether natural or added), on the nutrition information panel.

20 NlmUTlON LABELING · Descriptors for sodium content on the principal display panel as currently defined by FDA and USDA, should be continued. Potassium Severe fluctuations in potassium levels can be life-threatening. Some studies have suggested that increased dietary potassium may lead to a reduction in blood pressure. Current FDA regulations allow, but do not require, declaration of potassium on the nutrition label. USDA's policy is identical to that of FDA. The Committee recommends that: Disclosure of potassium content on the nutrition information panel should remain voluntary, unless a potassium claim is made. If disclosed on the label, potassium content per serving should be listed in milligrams. Vitamins and Minerals In the United States, dietary intakes of some vit~nins and minerals are current or potential public health issues, especially in some subgroups, but the majority of Americans are at no risk of deficiency. Under FDA's nutrition label- ing regulations, seven micronutrients are required to be listed as a percentage of the U.S. RDA (vitamins A and C, thiamin, riboflavin, niacin, calcium, and iron). Micronutrients would also appear in the ingredient listing when added to the product as individual ingredients. Any of these micronutrients, although most commonly calcium, iron, and vitamin C, are frequently featured on the principal display panel of foods by a descriptive term signifying their presence in a notable amount. Each of the seven vitamins and minerals, and any over voluntarily added, must be listed in the nutrition information panel as a percent- age of the U.S. RDA, regardless of the label present. Vitamin A Vitamin A is critical for such functions as vision and He im- mune system. Some carotenoids without vitamin A activity may have anticancer properties. Vitamin A deficiency is generally rare among Americans, Rough inadequate intake is found in some children under age 5 or people with chronic fat malabsorption. Vitamin A has been accorded status as a potential public health issue. B Vitamins Thiamin, riboflavin, and niacin are readily available in the diets of most Americans, and the incidence of deficiency is relatively rare, except among individuals whose health is already compromised Vitamin B6 deficiency, which rarely occurs, is usually observed in those who are deficient in several

SUMMARY 21 B-complex vitamins. Folate intakes are generally adequate. Folate and vitamin B6 have been accord status as potential public health issues, whereas thiamin, niacin, and riboflavin are not current public health issues. vitamin C Dietary deficiency of vitamin C can eventually lead to scurvy which has been observed in the United States in infants fed diets consisting exclusively of cows' milk and in elderly individuals who are on inadequate diets. Concern about vitamin C adequacy extends to individuals with low dietary intakes, cigarette smokers, and the poor. Therefore, it has been accorded status as a potential public health issue. Calcium Although the mechanism is not well understood, adequate cal- cium intake during the formative years, when it is most efficiently absorbed, is believed to reduce the risk of osteoporosis. Calcium absorption often is impaired in elderly individuals, affected by other dietary factors and hormonal changes. Increased calcium intake has been associated with a reduction in blood pressure in some studies, although this is not yet conclusive. Because of low calcium intakes by women and its possible association with age-related osteoporosis, calcium has been accorded status as a current public health issue. Iron Iron's most critical role is to carry oxygen to body tissues. Inade- quate intakes of dietary iron can ultimately lead to anemia Iron deficiency is primarily observed at 6 to 48 months of age, during adolescence, and during the female reproductive period, and therefore has been accorded status as a current public health issue. Although adequate intakes of micronutrients are important for all ages groups, intakes of a few of the seven vitamins and minerals that are currently listed on nutrition labels are current public health issues for Americans. Certain micronu~ients are potential problems in specific subgroups, such as children and women of childbearing age. As a result, there seems to be little reason to continue to require all seven micronutrients to be listed, and the focus should be on those that represent clearly identified problems. The Committee recommends that: · FDA and USDA should continue to require disclosure of calcium and iron content per serving, but using source descriptors (i.e., very good source of, source of, and contains). · FDA and USDA should allow, as an option, disclosure of the content of all other micronutrients for which RDAs exist. · FDA and USDA should establish standardized definitions for the terms used to describe the micronutrient content of foods on the principal display panel and these definitions should be the same as those used on the nutrition information panel as described for calcium and iron.

22 NUFRlTlON LABEl~NG PRESENTATION OF LABEL INFORMATION Serving Size The concept of serving is currently used as a reference unit for information about the nutrient content of foods. FDA regulations define serving to be the actual amount of a food likely to be consumed at a single setting or the portion of the food likely to be used as an ingredient. Nutrient information is declared in relation to the average or usual serving. Serving is also used as a tool for food and nutrient composition data bases and in dietary guidance systems that advise consumers about the number of daily servings of foods from each food group they should consume. A number of studies have shown that a large proportion of respondents cannot accurately judge the amounts of foods and beverages they consume. There is a tendency to overestimate serving sizes, with the magnitude of the error varying with the specific food item and experience in food preparation. There is currently wide variation in the size of servings declared on food labels, both between categories of foods and among foods in the same product category. It is frequently possible for two products with similar nutrient content to have different serving sizes. The ability of manufacturers to set serving sizes allows them to portray foods in the most favorable light to attract consumers. EDA has frequently voiced concern about the confusion in the marketplace caused by the practice of manufacturers to set serving sizes enhance the attractiveness of a product's nutritional value. This problem is further compounded by the use of nutrient descriptors. Several alternatives to seeing size as the reference unit for nutrition in- formation have been suggested, such as per 100 grams, and entire package. Although no reference unit is ideal, expressing nutrition information by serving seems to be preferred by consumers, health professionals, and food manufac- turers. The Committee recommends that: Given the alternatives available (serving size, nutrient values per package or container, 100 g portions), serving should continue to be He reference unit for presenting nutrition information on foods. Serving sizes should be expressed in common household measures, fol- lowed by the weight in grams (in parentheses) to facilitate comparisons across product categories. Serving sizes should be standardized across food categories on the basis of volume or weight measures. All serving sizes should be rounded down to the nearest whole number. · The number of servings per package or container should continue to be specified. For a single-serving container, 50 to 150 percent of the commonly

SUMMARY . 23 consumed unit would be acceptable. The number of servings per container should be rounded down to the nearest in whole number. Consistent with the recommendation that serving sizes should be standard- ized, quantities specified by dietary guidance recommendations should serve as the main criteria for selecting the amount of food to be described as a serving. This preference for recommended amount, rather than consumed amount, has the advantage that it can be more readily applied in educational programs and will ensure consistency among serving sizes as presented in dietary guidance materials and on He food label. FDA and USDA should, jointly, establish serving sizes for a limited number of different food categories, (i.e., fruit juices, breads, cereals, fruits, vegetables, spreads, and salad dressings) since serving size information will be more valuable to consumers if it applies to broad categories of food. The Committee favors fewer, rawer than more, categories so that nutrition information can readily be used by consumers for product comparisons and reference purposes. If a food manufacturer desires a serving size different from that set by the agencies, it should be permitted to petition the responsible agency to allow a deviation or to create a new subclass of foods with its own serving size. FDA and USDA should establish uniformity in serving size specifications within product categories and between agencies to facilitate comparisons among products, labels, point-of-purchase information, and federal and private data bases. Research should be conducted to determine how consumers comprehend food label information and how they interpret seeing sizes declared on the food pacl~ge. U.S. Recommended Daily Allowances The U.S. RDA reference standards were set in 1972 based on Be 1968 RDA (which have since been updated several timesy, generally at the highest level of RDA recommended for any age or sex group in the population. The amounts of protein, vitamins A and C, thiamin, riboflavin, niacin, calcium, and iron per serving as a percentage of He U.S. RDA are currently required to be declared on the nutrition information panel. Amounts are expressed in 2 percent increments up to the 10 percent level, 5 percent increments up to the 50 percent level, and 10 percent increments above 50 percent. Nutrients present in amounts of less than the 2 percent are indicated by a zero or an asterisk, which refers to a statement at the bottom of the table indicating Hat the product "contains less than 2 percent of He U.S. RDA of these nutrients." When a vitamin or mineral is added to a food or a claim is made about any nutrients, He percentage of the U.S. RDA must be declared for all seven vitamins and minerals. No claim

24 NUTRITION LABELING can be made that the food is a significant source of a nutrient unless a serving of the food contains 10 percent or more of the U.S. RDA of the nutrient per serving. The Committee recommends that: · The U.S. RDAs (or different reference term) should be update, even if they are to play a more limited role in nutrition labeling in the future. FDA and USDA should require the use of the descriptors very good source of, good source of, or contains to characterize the content of required or optional micronutrients in foods. Use of the descriptive terms on the nutrition information panel would require that micronutrient meet the following or similar criteria use of very good source of must provide, in a serving, more than 20 percent of the dietary standard for a given vitamin or mineral; use of good source of must provide, in a serving, 11 to 20 percent of the dietary standard for a given nutrient; use of contains must provide between 2 and 10 percent of the dietay shard for any nutrient; and a manufacturer would not be required or allowed to declare any nutrient present at less than 2 percent of the dietary standard. Ingredient Labeling The ingredient listing can be an important source of information about the nutrient composition of packaged foods. FDA and USDA require that ingredients be listed by their common names in their order of decreasing predominance by weight. The most significant exception to the general requirement that ingredients be disclosed is for foods covered by an FDA standard of identity for which only optional ingredients may be required to be labeled. Although FDA lacks the authority to require the labeling of mandatory ingredients, it has taken steps to amend existing standards to recharacterize most ingredients as optional. USDA requires ingredient labeling on standardized foods. The exemption of any standardized foods from mandatory ingredient Labeling can no longer be justified. The Committee did not take a position on percentage ingredient labeling because it viewed the issue as having no nutritional significance, although it may have merit for other reasons. The current format for the ingredient listing has been criticized. Ingredients typically appear as running text and often are printed entirely in capital letters separated only by commas, with no breaks or classifications and some use of parenthetical phrases to describe functions. Several useful proposals have been suggested to make this portion of the label easier to lead, including required use of capital and lowercase letters, separation of major from He minor ingredients, and the use of contrasting colors. Efforts should be made to improve the readability of Be ingredient listing to aid consumer understanding of me nu~idonal characteristics of different foods.

SUMMARY 25 The Committee recommends that: Congress should amend the FD&C, FMI, and PPI Acts to make clear that the general requirement of full ingredient listing applies to standardized as well as nonstandardized foods. · FDA and USDA should take steps to amend their regulations for ingredient labeling to require that the ingredients of s~ardized foods that are incorporated into other processed foods are declared by name on the label of the final product. · When EDA and USDA test different basic formats for nutrition labeling, they should also seek information about consumer reactions to and use of different formats for depicting the ingredients in foods. Food Standards of Identity FDA has established standards of identity for nearly 300 foods, most which have existed since the 1940s and l950s. These standards define the composition of products entitled to use the official product name. Some of these standards of identity have been criticized for impeding manufacturers' ability to offer more nutritious foods. The legal process for establishing and amending food standards of identity is extremely cumbersome, which discourages changes that would facilitate marketing of more healthful versions of products traditionally high in fat. In theory, standards of identity need not impede the marketing of reduced-fat or low-fat substitutes for foods traditionally high in fat but critics have claimed that FDA compliance policy discourages such innovations by precluding the use of standardized names on products that contain reduced levels of fat Although the Committee could not fully assess the criticisms of standards of identity, standards of identity certainly justify reexamination of the impact on efforts to develop more healthful versions of well-known foods. The Committee recommends that: · FDA's food standards should be carefully examined for their effects on the marketing of low-, lower-, and no-fat substitutes for high-fat foods. · Congress should amend the FD&C Act to eliminate the requirement that standards be adopted and amended through formal rulemaking procedures. · Congress should eliminate the exemption from full ingredient labeling for standardized foods. Descriptors Product labels have long been used for promotional as well as informational purposes, and food marketers give careful consideration to every facet of

26 NUTRITION LABELING label design. Although many facets of food labels are regulated, manufacturers nonetheless have considerable choice in the information that they include and the manner in which it is displayed within the constraints of label and package size. Growing consumer interest in nutrition and specific nutritional components has led many manufacturers to feature the desirable characteristics of products. Common examples in this practice are so-called nutrient content descriptors, such as low-calorie, fat-free, no cholesterol, fiber-rich, and lite. The proliferation of these descriptors and the growth in their usage have drawn attention from regulatory bodies, health professionals, and competitors. On the one hand, their popularity signals an encouraging interest among con- sumers about the links between nutrition and long-term health. On the other hand, the potential for confusion, exaggeration, and outright deception has prompted some to argue that nutrient content claims should be forbidden al- together. The problem stems in part from failure of the current system to regular such claims in a systematic way. Users of many content descriptors have no official definition against which to basis their claims. USDA reviews all labels individually and does not approve a label that carries an unapproved claim. FDA lacks standard definitions for most of the descriptors in common use, and at times is hampered in its efforts to prevent the use of terms in the absence of formal definitions. FDA has often relied on compliance with informal advice which depends on manufacturers' knowledge and their willingness to adhere to informal policy. Compliance with FDA's criteria is as likely to be related to the practices of competitors as to the views of agency officials. The problem is compounded when one agency has defined a descriptive term in official guidelines, but the other has not' or in the case where there are descriptors whose meanings the two agencies dispute. Without official uniform definitions of common descriptors, food manufacturers are able to exploit consumer interest in foods that appear to be healthful. For example, the tend lite or light has been used to imply fewer calories, reduced fat, lower sodium, improved texture, flavor, or color, and even the amount of breading, depending on the product. There are other practices that border on the deceptive. Although it is common to highlight desirable components of foods, rarely is there any effort to provide balanced information about other undesirable characteristics. For example, it may be literally truthful to label a food as containing no cholesterol, but even so, this may mislead consumers if it also contains substantial amounts of total fat and saturated fatty acids, particularly for unsophisticated consumers who equate cholesterol with fat. The responsible, restrained use of content descriptors may provide benefits to consumers who use them to hastily compare the main nutritional features of various foods. To promote the proper use and to aid consumer understanding of such descriptors, it is important Hat appropriate word definitions and criteria for their use be established. It is also important

SUMMARY 27 that the definitions established be the same for both agencies. Such quantitative descriptors are widely used and thus are of particular concern. The Committee readily age on these elementary propositions. It found the challenge of formulating definitions for the growing variety of content descriptors in common use considerably more difficult. Each example that it undertook to evaluate seemed to present distinctive issues, and the judgments reflected in existing agency regulations and guidelines governing the use of specific terms seemed heavily influenced by precedents that cannot readily be appreciate It quickly became clear that the Committee's work schedule would not allow the sort of in-depth study of agency policy and commercial practice that would be necessary to formulate recommendations for defining individual terms. The Committee was also persuaded that the agencies themselves probably cannot expect to establish formal definitions for all of the terms that inventive marketers are likely to adapt or invent to describe the nutrient content of foods. The goal should be to define a core set of the terms used to describe the most important food components fat, cholesterol, carbohydrates, Sber, and sodium. The agencies have made progress toward this goal. The Committee was concerned that further progress would be slowed if the agencies had to treat each component and associated set of descriptors—as presenting a unique problem. Accordingly, the Committee attempted to develop, and suggest for the agencies' consideration, a possible general framework for assigning nutrient values to such terms as low, very low, and reduced. The Committee's suggested framework would allow He use of quantitative descriptors limited to two categories high, low, very high, very low- with demarcations established for each descriptor. A scheme of benchmark ranges would be established for all quantitative descriptors for each nutrient based on the RDAs and other recognized dietary recommendation standards, and benchmark limits would be kept conceptually consistent for all nutrients in order to simplify the message. The use of comparative descriptors should be strictly regulated, with clear identification of the products being compared. In addition, the extent of nutrient modification should be specified and based on a modification of at least 20 percent' and descriptors should not be allowed for nutrients unless they are normally present in physiologically significant amounts (when physiologically significant amount is defined, such as 1 percent of the maximum allowance used to define the limits for very low). Synonyms of approved descriptors should not be allowed except by petitioning FDA and USDA; and descriptors that characterize other features that are not directly nutritional in nature (e.g., organic, fresh, and napalm should be controlled by narrowing the conditions for their use. Finally, the Committee believes that descriptors that imply mitigation or cure of disease or health condition should be controlled under Be regulations being developed for health claims.

28 NUTRlTlON LABELING Comparative descriptors, such as reducedfat, are also widely used on many foods. Often, the compared food is not identified, and just as often the difference between the products is not described quantitatively. Use of such comparative terms should require clear identification of the product being compared and specification of the extent of modification. Descriptors that proclaim the absence of an undesired component, such as cholesterol free, should not be allowed on foods that do not normally contain cholesterol. And when used on foods that contain significant amounts of fat, or another undesired component, such as sodium, such claims should be accompanied by a disclosure of that fact. Label Format Options In 1972, when the voluntary nutrition labeling program was being devel- oped, PDA investigated the various options that might be used to convey the nutrition information on the package and decided to use a numeric presenta- t~on. In 1982, FDA commissioned a study to develop alternative label formats, but systematic consumer testing was not undertaken. Some research has been done on the effectiveness of the current label format and various alternatives . . . to convey nutrition Information to consumers. Alternative presentations have included descriptors, graphics nutrient density with and without graphics, food equivalents calorie-based, and symbols. When any of these alternatives have been evaluated against the current format, consumers generally say they prefer the graphic format, yet they also seem to prefer nutrition information stated in absolute numbers and percentages over the alternatives. Research on nutrition information provided at the point of purchase suggests that the form of presentation has an impact on the format judged to be most useful. Control over the individual's information input rate and ability to process data at a comfortable pace seem to reduce confusion. In addition to the recommendations listed earlier on the mandatory and voluntary disclosure of nutrient content information, the Committee recommends that Serving size should be prominently displayed on the nutrition information panel and should appear in household units. The amount of the serving should appear in grams or milliliters in paren- theses following household units. Nutrient information should appear for the food as it is packaged, with the option of providing information relevant to the manner in which the food is prepared · Macronutrients should be listed in grams or milligrams. · Macronutrients should be listed first, and then other food components, elec- trolytes, and micronutrients, or similar food components should be grouped together, except fiber and cholesterol should not appear in groupings.

SUMMARY 29 · Vanous issues related to placement and prominence of food components on the nutrition label (e.g., increased prominence of fat components, ordering of macro- and micronutrients) should be subjected to consumer testing. · Comparison with dietary recommendations should be optional. Consumer Testing Alternative label formats should be subjected to both qualitative and quan- titative consumer testing prior to issuance of any final nutrition Labeling require- ments. However, this testing must be carefully structured to produce measurable results and, given the level of expectation for this process, carried out within a reasonable period of time. It is also assumed that before any testing procedures begin, the agencies will have determined through the comment and rulemaking process the nutrient content information to be conveyed on the label as this will affect the required nutrition information to be presented in any format tested. The Committee recommends that: A brief test panel education program reviewing the current dietary rec- ommendations and explaining me basics of the new label formats should precede label format testing. A formal testing procedure should include: an advisory panel to help de- termine the formats to be tested; an initial testing phase to include a com- prehensive, qualitative review by consumers; an in-depth evaluation of He most preferred choices to assess consumer ability to use label information; and finally, large-scale surveys to determine consumer acceptance and com- prehension of label information. Educating Consumers to Use Nutrition Information on Food Labels Two general strategies have been described for promoting dietary change. Environmental or structural interventions are strategies that encourage positive behaviors by creating opportunities for action and removing barriers so that consumers can follow health-promoting behaviors. In terms of dietary change, modification of some aspect of the food supply or improvement of consumer access to food would represent such a change. Personal or direct influence strategies are based on providing information or directing educational efforts, persuasion, and behavior modification techniques toward individuals or small groups. Techniques in these areas evolve from simple information transmission (based on the premise Hat knowledge of the facts will change behavior) to a variety of direct behavior modification techniques that are designed to lead directly to He development of heal~-promodng skills and practices.

30 Nlm=70N LABELING The nutrient composition information provided on food labels should enable the public to make informed food choices. The provision of nutrition information on food labels is an amalgam of these two strategies: it is an environments strategy because the federal government adopted an information provision policy by allowing not only nutrition information to appear, but also by setting the rules governing format, content, and placement, a personal-influence strategy for consumers to have the information to use. Various public information campaigns aimed at promoting healthy behav- ior (including those for heart disease, high blood pressure, and cancer) have focused on enhancing knowledge, changing attitudes, and improving skills. Un- fortunately, research suggests that improving consumer knowledge and consumer attitudes alone will not result in adoption of health-promoting practices. Con- sumers need information to make long-term dietary changes, but they need more than just information to achieve this goal. Educational resources will be required to effect behavioral change. Obstacles to effecting dietary change in consumers include factors that are both cultural and psychological in nature. Most diet-related health problems develop gradually, without immediate or dramatic symptoms. Risk factor reduc- tion and disease prevention through dietary means require an individual to make long-term and often arduous changes in food habits. However, many Americans consider themselves reasonably healthy and question whether major alterations in their dietary habits will be worthwhile in the long non. A comprehensive national nutrition policy would ensure the availability of adequate supplies of safe and nutritious foods as well as provide consumers with the educational means for making informed food choices. A well-designed nutrition labeling program is an important component of an education program, but the provision of information is only the first stage in the behavioral change process. It cannot substitute for a comprehensive nutrition education program. The Committee recommends that: . Public- and private-sector initiatives should be established to help consumers understand and apply the information on the nutrition label. · Comprehensive nutrition education programs should be developed in order to help consumers to understand the information on food labels to enable them to plan diets and make appropriate food choices. Costs of Labeling Reform Any reform of food labeling to provide more complete nutrition information and any expansion of the coverage of current nutrition labeling requirements will impose costs on producers, manufacturers, retailers, and ultimately, consumers regardless of who is recommending reform. It is the Committee's ju~nent that its recommendations for the content of nutrition labeling would require very little

SUMMARY 31 information that producers do not already possess. The timing of the imposition of such requirements could affect the cost of compliance. For foods that do not now bear nutrition labeling of any sort, additional costs will be incurred. The costs of analysis of these foods may not be trivial, though adequate methods and laboratory resources are available to analyze, at a reasonable cost, virmally all packaged foods for all of the nutrition components that the Committee recommends. Providing point-of-purchase nutrition information on produce and fresh meat, poultry, and seafood will impose significant new costs on remilers and consumers. The Committee is recommending that limited-menu restaurants be required to display point-of-purchase nutrient content information on their foods and that all other restaurants be required to have such information available to consumers on request. This recommendation is not likely to entail substantial additional costs, either for the limited-menu restaurant or consumers. The cost to require all other restaurants to have their menus evaluated and to offer nutrient information on request to consumers are considerably less certain. However, evaluation of the nutrition profile of menus is widely available and inexpensive, but even modest expense may prove high for small operators. LEGISLATION AND REGULATION The charge to the Committee to consider the implications of its recom- mendations for the current laws governing nutrition and ingredient labeling was interpreted as an invitation to consider whether the laws or regulations under which FDA and USDA now regulate food labels need to be changed in order to implement food labeling reform. It is the Committee's view that Congress should amend the FD&C, FMI, and PPI Acts to confirm FDA's and USDA's authority to expand the coverage and revise the content of current nutrition label- ing requirements. Continuing doubt about the existence of such authority may impede actions by the agencies and result in court challenges, thus delaying implementation of needed reforms. The Committee believes, however, that even without new legislation FDA could mandate nutrition labeling on all packaged foods. FDA's authority to prescribe the format and content of nutrition information, when it is required on food labels, appears well established as a means to prevent misleading labeling. In addition, FDA's decisions to exempt certain foods from some or all nutrition information requirements would likely be upheld. Point-of-purchase nutrition information for produce, seafood, and foods sold in restaurants would represent a whole new area of regulation for food labeling. Most experts consulted by the Committee agreed, however, that if FDA could establish its authority to mandate nutrition labeling on foods in general, the extension of such a requirement to produce, seafood, and foods sold in restaurants would also be upheld as a matter of statutory authority. However, the practical problems associated with this expansion of nutrition labeling would be

32 NUTRITION LABELING significant. FDA would have to devise an alternative to the conventional package label and would have to devise an alternative means for determining nutrient composition. FDA has frequency held the position that it has the authority to regulate He labeling of produce and foods sold in restaurants, although problems of enforcement and low priority have led it to refrain from exercising this power. USDA's authority to expand nutrition labeling of processed meat and poultry products appears more straightforward. The PHI Act requires a label to be affixed to any meat product package, although He EMI Act does not grant general authority to USDA to require affirmative disclosures of infonnabon, nor is omission of this information classified as misleading. Section 607(c) of the PHI Act empowers USDA to prescribe the material required in nutrition labeling to avoid false or misleading statements, suggesting that nutrition information can be required on meat products whenever the Secretary of USDA concludes that it is required to prevent the label from being misleading. The same authority can be assumed under the PPI Act. USDA has ceded the authority to regulate the packaging of retail fresh and frozen meats and poultry to local agencies. USDA's authority to prescribe nutrition labeling for meat- and poultry- containing foods sold by restaurants is more problematic. This uncertainty is of concern to He Committee, because it believes that both federal agencies should require nutrition information for foods sold at least by limited-menu restaurants. Desirability of New Legislative Authority for Nutrition Labeling The foregoing discussion suggests why new legislation is, in pnnciple, desirable. The Committee does recommend that Congress amend the FD&C, FIJI, and PPI Acts to enlarge and clarify the authority of FDA and USDA, but it acknowledges that this has costs as well as advantages. Disadvantages of New Legislation A drawback to seeking new legislation is the possibility that such an effort may fail, causing both agencies to rethink their authority to proceed with changes in existing regulations. The second disadvantage stems from the propensity of Congress to draft legislation in such detail as to hamper administrative responses to new problems. Congress could simply require all food to bear nutrition Labeling and state Hat FDA and USDA are to determine its content. It seems unlikely, however, that Congress will refrain from specifying the content of nutrition labeling in detail. Purtherrnore, new legislation could exclude important categories of foods, such as produce, seafood, meats and poultry, or foods sold in restaurants. Because the Committee is persuaded that nutrition labeling should be required for all these foods, it would consider legislation that categorically exempted or omitted Hem to be unsound in principle and at odds

SUMMARY 33 with efforts to improve the dietary habits and long-term health of Americans. An additional concern is that new legislation might encumber FDA and USDA with rulemaking procedures that would delay implementation of regulations requiring more informative nutrition labeling. Advantages of New Legislation An overriding advantage of new legislation is that it could lay to rest any doubt that FDA and USDA have the legal authority to mandate. nutrition labeling for all packaged foods and clarify this authority to require nutrition information in connection with the sale of many foods that currently are not affected by federal labeling regulations. It would also reduce the incentives to challenge agency regulations that implement the Committee's recommendations. New legislation could also expedite the administrative process by confirm- ing the power of the agencies to proceed by informal rulemaking. And it could speed executive branch review by setting deadlines for proposing and promul- gating initial regulations. Successful reform of nutrition labeling requires that FDA and USDA work in tandem so that consumers can eventually make food selections in keeping with recent dietary recommendations. Legislation should mandate that the requirements of FDA and USDA be uniform and implemented on the same schedule. Another justification for legislation is the importance of food labeling reform. The stakes involved make Congress the appropriate arena for resolving the critical issues and adjusting to the competing interests. Design of Food Labeling Legislation New legislation should clarify the authority of FDA and USDA to mandate nutrition labeling on all packaged foods and coverage of fruits and vegetables, fresh and frozen meats and poultry, fresh and frozen seafood, and foods sold in restaurants. The next issue concerns what new legislation should provide regarding He content of labeling. A distinction should be drawn between those components of nutrition labeling Mat should be required by FDA and USDA regulations and those that should be mandated by statute. Legislation should limit itself to prescribing calories per serving, complex carbohydrates, sugars, and those components whose consumption should be restricted or curtailed (fat saturated fat, cholesterol, and sodium). All other components to be included in nutrition labeling should be left to FDA and USDA. The Committee expects that, in addition, the agencies would agree to requiring protein, fiber, calcium, and iron. New legislation should direct the two agencies to agree on the same reference unit for listing nutrition information, presumably a serving of food. It

34 NUTRITION LABELING

SUMMARY 35 and would perhaps induce federal authorities to fashion their requirements to reflect the interests of the states. Establishment of such a food labeling committee would not require new legislation, but a congressional mandate would ensure creation of such a mechanism. Finally Congress should establish deadlines for adoption of new food labeling regulations by the agencies.

Next: Part I: Current State of Nutrition Labeling »
Nutrition Labeling: Issues and Directions for the 1990s Get This Book
×
Buy Paperback | $70.00
MyNAP members save 10% online.
Login or Register to save!
Download Free PDF

Nutrition Labeling offers a thorough examination of current nutrition labeling practices and recommends ways to make food labeling information consistent with recent dietary recommendations from the U.S. Surgeon General and the National Research Council.

The volume proposes implementing a food labeling reform program, addressing such key issues as requiring mandatory nutrition labeling on most packaged foods, expanding nutrition labeling to foods that do not currently provide this information, making federal requirements uniform between agencies, and updating the nutrient content and format of food labels.

  1. ×

    Welcome to OpenBook!

    You're looking at OpenBook, NAP.edu's online reading room since 1999. Based on feedback from you, our users, we've made some improvements that make it easier than ever to read thousands of publications on our website.

    Do you want to take a quick tour of the OpenBook's features?

    No Thanks Take a Tour »
  2. ×

    Show this book's table of contents, where you can jump to any chapter by name.

    « Back Next »
  3. ×

    ...or use these buttons to go back to the previous chapter or skip to the next one.

    « Back Next »
  4. ×

    Jump up to the previous page or down to the next one. Also, you can type in a page number and press Enter to go directly to that page in the book.

    « Back Next »
  5. ×

    To search the entire text of this book, type in your search term here and press Enter.

    « Back Next »
  6. ×

    Share a link to this book page on your preferred social network or via email.

    « Back Next »
  7. ×

    View our suggested citation for this chapter.

    « Back Next »
  8. ×

    Ready to take your reading offline? Click here to buy this book in print or download it as a free PDF, if available.

    « Back Next »
Stay Connected!