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7 Presentation of Nutrition Infor~nation on Food Labels CRITERIA FOR PRESENTING INFORMATION To assure that the nutrition information provided on a food label is conveyed in a manner Hat will allow the majority of consumers to use it successfully, a number of criteria need to be considered, including literacy of users, com- putational abilities, knowledge of English, and knowledge of the specialized vocabulary of nutrition labeling. The actual label presentation scheme needs to make it possible for consumers to understand the nutrition contents of individual food products, compare nutrition contents across product categories, and choose among relevant food alternatives. REFERENCE UNITS FOR DECLARING NUTRIENT CONTENT (SERVING SIZE) In assessing the adequacy of current food labels, the element of serving size affects the usability of all other label components. Over a decade ago, the Food and Drug Administration (FDA) indicated that, "serving size has been one of the issues that has most concerned consumers and manufacturers alike" (DHEW/USDAIFIC, 1979, p. 77~. Concept of Serving Originally, the concept of serving was geared to the actual amount likely to be consumed at a single sitting. However, the concept of serving size is currently used to provide a reference point for information about the nutritional 203

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204 NU1771T ON LABELING and other qualities of the food product. Once seeing size is regarded as a standard unit rather than as an estimate of likely consumption, it is possible to visualize varying amounts for similar products, such as a 2-oz serving size for canned tuna and a 3.5-oz serving size for salmon. For maximum usefulness and understanding, however, labeled seeing size should not depart widely from the amount normally consumed at one time. Nutrient information on food labels under FDA and U.S. Depar~anent of Agriculture (USDA) jurisdiction is declared in relation to the average or usual serving, or, when the food is customarily used as an ingredient, in relation to the average or usual portion. The FSIS Standards and Labeling Policy Book and policy memoranda simply stipulate that "when a label contains a statement or claims identification of the number of servings, it must be qualified to identify the size of the servings, e.g. 3, 2 oz settingsor, 1-6 oz seeingor, 3 portions, 2 oz each" (USDA, 1989b, p. 139~. In the dietary assessment literature, seeing size is typically regarded as a term for a standardized or commonly ingested portion of food. In contrast, portion size refers to that amount of food reported to be ingested at an eating occasion. Definitions There is considerable confusion among three terms: serving, portion, and helping. The term serving was defined by FDA as a reasonable quantity of food suited for or practicable of consumption as a part of a meal by an adult male engaged in light physical activity, or by an infant or child under age 4 when the article purports or is represented to be for consumption by an infant or child under age 4 (21 CEK 101.9(b)~1~. In contrast, FDA defined the term portion as the amount of food customarily used only as an ingredient in the preparation of a meal component, e.g., Y2 tablespoon of cooking oil or \/4 Cup of tomato paste. FDA has further specified that servings and portions must be expressed in terms of common household measuring units or other easily identifiable units such as cups, tablespoons, ounces, or slices. Disparities in Serving Sizes Sewing size is provided as a tool for consumers and users of dietary guid- ance information, nutrient composition data bases, food consumption research, and on food Labels. There are great variations and wide disparities in the in- forrnation presented to consumers in each of these domains for the same foods or for items in the same product categones. A comparison of the seeing sizes specified by various dietary guidance plans, used in food composition data bases, amounts actually consumed, and the range currently shown on food labels is presented in Table 7-1.

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PRESENTATION OF NUTRITION INFORMATION ON FOOD LABELS Serving Size Information as Portrayed in Dietary Guidance Materials 205 Dietary guidance systems provide information to consumers about the individual foods they are advised to consume. The common approach has been to recommend a number of daily servings of each of several food groups. In some, but not all, cases the sizes of settings are specified. In 1958 the Basic Four food guide, officially known as Food for Fitness: A Daily Food G - e, was developed by USDA nutritionists (USDA, 1958~. That guide recommended "some mild for everyone," with servings from the mild group of 2 or more cups a day for adults to 4 or more cups a day for teenagers. However, no sizes were specified for the number of servings of food from the meat, vegetable and fruit, or bread and cereal groups. In 1980 and 1985, dietary guidance information was presented to consumers in Nutrition and Your Health: Dietary Guidelines for Americans, but these advisory statements made no specific quantitative recommendations. Instead, they offered seven qualitative, directional statements, such as "eat a variety of foods," "eat foods with adequate starch and fiber," and "avoid too much . . ." (USDAIDHHS, 1980, 1985~. The third edition is expected to provide essentially the same type of directives (USDA, 1990~. In the late 1980s, USDA developed and published a food guidance system, using both a menu planning strategy and commonly used food guides that did specify serving sizes (Cronin et al., 1987~. The pattern for daily food choices recommended consumption of 6 to 11 servings of grains, breads, and cereals; 2 servings of milk, cheese, and yoglrt; 2 to 3 servings of meat, poultry, fish, and eggs; 3 to 5 servings of vegetables; 2 to 4 servings of fruits; and moderate amounts of fats, sweets, and alcohol. In general, amounts of food that counted as a serving were based on typical serving sizes reported by individuals in the 1977-1979 Nationwide Food Consumption Survey conducted by USDA. A typical serving of food was defined as "the median amount of food consumed at a single eating occasion." The amounts of typical servings were specified for food groups and are shown in Table 7-1. The National Research Council (NRC) report, Diet and Health: Implica- tions for Reducing Chronic Disease Risk MARC, 1989a), advised that consumers should "every day eat five or more servings of a combination of vegetables and fruits" and should "increase intake of starches and other complex carbohy- drates by eating six or more daily servings of a combination of breads, cereals, and legumes." The average serving of these foods was defined as "equal to a half cup for most fresh or cooked vegetables, fruits, dry or cooked cereals and legumes, one medium piece of fresh fruit, one slice of bread, or one roll or muffin" (NRC, 1989a, p. 15~. For the most part, the various sources of authoritative dietary advice offer fairly consistent messages about recommended serving sizes for products in the same categories (Table 7-1~. However, it remains to be determined whether

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206 NllTRITION LABELING TABLE 7-! Serving Sizes as Depicted by Several Means for Selected Food Dietary Guidance Recommendations Diabetic USDA Food Diet and Exchange Basic Four Guidance Food Item Healtha Lists Food Groups Systems Grains Bread Muffin, bagel 1 Cereals, pasta, rice ll2 c Legumes, beans ll2 c Dairy 1 slice 1 slice _ e 1/2 c, ckd 3/4 C, my 1/3 C 1 slice 1 small Y2 c, ckd Mink, fluid 1 c 1 c 1 c Cheese 1 oz. low-fat 1~/2 oz natural, 2 oz processed Yogurt 8-oz carton 8 fl oz Fruit Fresh ll2 c 1 piece Average piece Juice ll2 c 6 oz Vegetable Cooked Raw Meat Ground beef Poultry Tuna (canned) Peanut butter Condiments Butter, margarine Catsup 2 c ll2 c 1 c 1 sm. hamburger /2 chicken breast ll2 c 1 T 1 t ll2 c 1 c raw 1 c leafy raw Total of 5 to70z Lean daily a NRC (National Researc h Council). 1989. Diet and Health: Recommmendations for Reducing National Research Council. National Academy Press, Washington, D.C. 749 pp. b American Diabetes Association and The American Dietetic Association. 1989. Exchange Alexandria, Va. 32 pp. c Cronin, F. et aL 1987. Developing a food guidance system to implement the Dietary d Krebs-Smith, S.M., and H. Smiciklas-Wright. 1985. Typical serving sizes: Implications for c Not specified. f Sandwich steaks.

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PRESENTATION OF NlTI771TION INFORMATION ON FOOD LABEL; Products 207 Food Composition Data Bases Food Labels Giant Food, Inc., (ranges for USDA USDA Home Food Guide selected As Consumed Handbook 8 & Gdn. Bltn. 72 (average) products) 2 slices 100 g 1 slice 2 slices 1-2 slices ~ 1 1 1 1 c, ckd rice " 1 c 1 c (approx) 1 oz (dry wt) t' 1 c 1/2 c 1/2 c lo " lc 8floz lo 1 ~/2 oz (males) n 1 OZ 1 OZ 1 OZ 1 oz (females) " " ~ oz 6 oz 6 oz container 1 med piece " 1 unit 1 piece 374 C n 1 C 6 fl oz 6 fl oz Y2 c " 1 c I/2 c 1/2 c 2 leaves (males) " 1 c 73 c lettuce Y2 c (females) " 3 oz ckd 2 ozf 6 oz daily (males), " 3 oz 1 oz 4 oz daily (females) " 3 oz 3 oz 2 oz " 1 T 2T 2T " IT IT IT " IT IT Chronic Disease Risk. Report of the Committee on Diet and Health, Food and Nutrition Board, Lists for Menu Planning. American Diabetes Association and Me American Dietetic Association, Guidelines. J. Nutr. Ed. 19(6):281-302. food guidance. J. Am. Diet. Assoc. 85:1139- 1141.

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208 NlmUTION LABELING consumers visualize or consume portions in the same sizes and dimensions as recommended. Serving Size in Nutrient Composition Data Bases The USDA Agriculture Handbook No. 8 series, Composition of Foods, comprise a group of technical publications that provide nutrient composition information for an extensive list of raw, processed, and prepared foods. It is now frequently updated and will consist of 22 sections when fully completed. This series of publications provides nutrient composition information based on 100-g portions of foods (USDA, 1976~. In an effort to compile a document that would be more useful to professional and technical personnel as well as researchers, USDA issued Nutritive Value of American Foods in Common Units (USDA, 1975~. In that publication, nutrient composition information was presented for approximately 1,500 foods in frequently used household measures and market units of food The measurements for specific quantities listed are the customary units now in use for the edible portion of the food item. For example, information for breads is presented both by the loaf and by the slice; for juices, cereals, and fluid milk, by 1 cup; for vegetables and fruits, by the piece or 1-cup portions; and for meats, by 1-pound or 1-cup portions or by the piece. A more concise document for consumer use is Nutritive Value of Foods, Home and Garden Bulletin No. 72, first published in 1960 and last revised in 1981 MISDO, 1981~. It provided a table of nutritive values for household measures of 908 commonly used foods grouped under 15 different main headings. Most foods were listed in ready-to-eat form, but some were basic products widely used in food preparation, such as flour, fat, and cornmeal. The Bulletin was careful to point out that The approximate measure shown for each food is in cups, ounces, pounds, some other well-known unit' or a piece of a certain size. The measures shown do not necessarily represent a serving, but the unit given may be used to calculate a variety of serving sizes. For example, values are given for 1 cup of applesauce. If a serving is Y2 cup, divide the values by 2 or multiply by 0.5; for a 43 Cup serving multiply values by 0.67 (USDA, 1981, p. 4~. Serving Size Reported by Consumers Data bases containing food consumption data taken from national surveys are another source of typical serving sizes. Pao et al. (1982) used 3-day reports from a weighted sample of about 38,000 individuals to determine the weights (in grams) of various foods eaten per meal or snack Krebs-Smith and Smic~las-Wright (1985) converted the amounts reported

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PRESENTATION OF NUTRITION INFORMATION ON FOOD LABEl~; 209 by Pao and fellow researchers to common household measures for several age and sex groups and used these amounts to determine the most common serving size for different foods. They showed that, for many food items, typically reported servings deviate considerably from the amount accepted as standard servings. Unlit juices, breads, and cereals were frequently consumed in larger amounts than expected, whereas quantities of raw vegetables, meat, fish, and poultry varied widely. Typical serving sizes of breads and cereals were usually twice the size found in earlier recommendations (2 slices versus 1 slice). The study by Hunter et al. (1988) of 194 women to determine the seeing sizes of 68 foods found that for most foods there was no usual seeing size even for foods that are in well-defined units, such as crackers. Guthrie (1984) reported that food portions self-sened by young adults deviated by more than 25 percent from the generally accepted serving size for 28 to 80 percent of the serving selections. Recently, FDA conducted a survey of the amount of food consumed per eating occasion from USDA's 1977-1978 Nationwide Food Consumption Survey and foods in the marketplace. The data were used to determine the standard seeing sizes for 159 food product categories and to define single- sening containers for its proposed rule on seeing size (55 Fed. Reg. 29,476- 29,533, July 19, 1990~. Research on Portion Size Estimation Dietary assessment research has examined the issue of whether consumers are able to provide realistic, valid estimates of the amount of food they consume. A number of the studies that have addressed this topic have documented that a large proportion of respondents cannot accurately judge the amounts of foods and beverages they consume. Both Madden et al. (1976) and Gersovitz et al. (1978) observed overreporting of low intakes and underreporting of high intakes in the subjects they studieda phenomenon commonly referred to as "regression to the mean." The conclusions from various studies on portion size estimation indicate that people do not give accurate estimates of the amounts of foods they consume. In general, there is a greater tendency to overestimate than to underestimate portion sizes, with the magnitude of the error varying with the specific food item (Goalie, 1984; Minsky and Brownell, 1982; Lewis et al. 1988; Webb and Yuhas, 1988~. Some studies have suggested that food preparation experience seems to help subjects better estimate the amounts of foods they consume, which may explain why women are better than men at estimating quantities of foods. Mining and the use of measuring utensils or food models have been shown to improve some estimates of sizes, but the results are not consistently relivable across all types of foods or memory aides used (Yuhas et al., 19891.

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210 Nl~RlTION LABELING Serving Sizes on Food Labels There is tremendous variability in Me seeing sizes currently declared as the reference standard on food labels in different product categories, among foods, and between foods in the same product category as shown in Table 7-2. Ready- to-eat breakfast cereals, perhaps, show the greatest variability, with serving sizes usually designated as 1 oz. regardless of the volume of the product; 1-oz volumes range from 21/2 tablespoons to 1 cup. Not only are the acts quantities not Me same for serving sizes for foods in the same product categories but the units of measurement also vary. For example, serving sizes may be expressed in ounces, units (such as pieces or sticks), cups, tablespoons, or teaspoons. When nutrition labeling was first introduced in 1973, it was left to indus- try to adopt reasonable serving sizes (21 CF1< lOl.9(b3~1~. After the nutrition TABS 7-2 Serving Sizes Currently Used on Food Labels (Selected sample of commonly used products Food Item ServingslPackage Serving Size or Container Breads Bread, white 2 slices (2 oz) 12 Bread, whole wheat 2 slices (1.7 oz) 9.5 Bread, cinnamon (Pepperidge Farm) 1 slice 16 Bagel (Lenders) 1 4 English muffin (Thomas') 1 6 Cereals looks Bran (Nabisco) 1 oz (Y2 c) 17 AllBran (Kellogg) 1 oz (y3 C) 13 Cream of Wheat (Nabisco) 1 oz (2~/2 T dry) _b Crispix (Kellogg) 1 oz (1 c) 12 Frosted Mini Wheats (Kellogg) 1 oz (Y2 c) 17 Fruit and Fibre (Post) 1.25 oz (y3 C) 12 Fiber One (General Mills) 1 oz (Y2 c) 13.5 Golden Grahams (General Mills) 1 oz (3~4 C) 18 Grape Nuts (Post) 1 oz (y4 C) 16 Instant Oatmeal (General Mills) 1 pkt (1.6 oz) 8 Instant Oatmeal (Quaker) 1 pkt (1 y4 OZ) TO Quaker Oat Squares (Quaker) 1 oz (Y2 c) Meat, poultry, fish Frankfurters Luncheon meat Sausage Fish sticks, frozen Salmon, canned Tuna, canned 10 1 slice 8 1 cooked path (33 g) 10 4 sticks 8 ll2 c 2 oz 4 3.3

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PRES~NT~ION OF NUTRITION INFORMATION ON FOOD LABELS TABLE 7-2~0ntinued 211 Food Item Servings/Package Serving Size or Container Beverages Diet soda 6 fl oz Orange juice, prepared from frozen cone. 6 fl oz Hawaiian Punch (drink box) 6 fl oz 1 pkt (6 fl oz) 10 6 fl oz 1.4 Hot chocolate mix Pink grapefruit juice cocktail Dairy Cream cheese Ice cream Mills Sour cream 2 8 1.4 1 oz ll2 c 1 c (S fl oz) Varies 2 T 8 Spreads Butter 1 T Margarine 1 T Mayonnaise 1 T 64 Fruits and vegetables Bluebernes, Dozen 4 oz 4 Fruit cocktail, canned i/2 C 7 Peas, canned \/2 C 4 Peas, frozen i/2 C 6 Tomatoes, canned i/2 C 4 Over Macaroni and cheese dinner, box 3/4 C (as prepared) 4 Noodles Alfredo, box l/2 C (as prepared) 4 Peanut butter, jar 2 T (32 g) 10 Pork and beans, canned i/2 C (130 g) 3.5 Potato ships, bag IS chips (1 oz) 7 Soup, canned, condensed 8 oz (as prepared) 2.5 Soup, canned, single serving 103/4 OZ 1 Spaghetti sauce, jar 4 oz 12 a Connation compiled from visits to local Washington, D.C., area supermarkets by L.S. Sims, 1990. Not specified. labeling regulations were implemented, FDA conducted an informal survey of product labels that provided nutrition information. The results of that survey indicated ~at, in many cases, serving sizes were not reasonable or uniform within a product class (39 Fed. Reg. 20,878-20,887, June 14, 1974~. In 1974, I;DA published proposed serving sizes for several foods, including fluid milk beverages, noncarbonated breakfast beverage products, hot and ready- t~eat cereals, and formulated meal replacements (39 ~d. Reg. 20,895-20,900, June 14, 1974~. Since then, a serving size has been proposed for soft drinks (40

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212 NUT~ION LABELING Fed. Reg. 4315~316, Jan. 29, 1975), and petitions have been received seeking to establish a portion size for flour and serving sizes for bread and peanut butter. However, the agency has taken no further action on either the proposed serving sizes or amending the portion size definition. As a result, FDA (and, consequently, USDA as well) does not specify serving sizes for any of the thousands of food products on the market. Rather, the manufacturer decides the serving size to be designated, subject only to the loose requirements that the serving size must be (1) a "reasonable quantity of food suited for or practicable of consumption as part of a meal by an adult male engaged in light physical activity" (or by a child, for foods intended for children) (21 CFIt 101.9(b)~1~), and (2) it must be expressed "in terms of a convenient unit of such food or a convenient unit of measure that can be easily identified as an average or usual serving and can be readily understood by purchasers of such food" (Heimbach et al., 1990~. Over time, a hybrid system for seeing size has evolved. For most foods, the declared serving size is neither an arbitrarily fixed amount that is uniform for similar products nor an average or usual serving, but rather is something in between a standard unit which is set by food manufacturers rather than by the federal government and is unique to each product type. FDA believed that declaration of the nutrition content in terms of a usual seeing of each different food product would be more flexible and more meaningful to consumers so that they could relate the label information to individual intakes. This rationale may still be valid, but it has allowed manufacturers to vary serving size declarations over time and manipulate label claims on the basis of per seeing nutrient contents. The significance of the chosen seeing size is magnified by the fact that all nutrient values declared on the label are dependent upon this determination. For example, jelly and jam produced by the same manufacturer listing 1 or 2 teaspoons, respectively, as serving sizes illustrates the problem. Both labels offer the same information, and a careful comparison would reveal that the nutrient contents of the two products are virtually identical. Clearly, neither label is inaccurate. Yet, consumers who choose products mainly by examining the calorie content may think that one product has twice the calories of the other, when the calorie content of equal portions of the products is essentially the same. The leeway given to manufacturers to set serving sizes offers them the opportunity to portray each food item in the most favorable light. In 1979, FDA expressed concern that"some manufacturers were using overly large serving sizes to inflate the nutritional value of their product in order to enhance its attractiveness (DHEW/USDA/E1C, 1979, p. 77~." The commercial rationale for doing so was the belief Hat consumers were seeking foods on the basis of increased nutritive value and, in particular, higher protein, vitamin, and mineral contents. FDA noted that the serving sizes recommended for many canned

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PRESENTATION OF NlJTRITION INFORMATION ON FOOD l,ABELS 213 fruits and vegetables, as well as for some varieties of canned tuna, flit juices, and frozen vegetables, had approximately doubled (in amount) since nutrition labeling was initiated Ten years later, the concern is that manufacturers have begun shrinking serving sizes in response to consumers' tendency to use label information for avoiding particular food constituents such as fat, sodium, and cholesterol (Heimbach, 1985, 1986, 1987~. This tendency may be encouraged by current definitions of descriptors such as low sodium, which is based on a sodium content of less than 140 mg per serving. For example, an 8-oz food package that contains 360 mg of sodium does not qualify for a low-sodium descriptor if it is labeled as providing two 4-oz servings (with 180 mg of sodium per serving), but it may be labeled as low sodium if the package is declared to contain four 2-oz servings. Recent data from PDA's Food Label and Package Survey have shown that 19 of 44 product classes and both bread categories (white and nonwhite) moved toward smaller declared serving sizes in the period from 1977 to 1986 (Heimbach et al., 19903. The information contained in Table 7-2 dramatizes the considerable variability in serving size information on food labels, even for foods within the same product categories. In some cases, food manufacturers keep the serving size unit constant and vary the volume of a serving or a container. For example, the serving size of ready-to-eat breakfast cereal is routinely listed as 1 oz. but the volume varies tremendously (from 2~/2 tablespoons to 1 cup of cede due to the wide variation in the densities of different products. Another example is juice, which is routinely listed as a 6-oz serving, but the number of servings varies from 1.4 to 8 per container. In other cases, the recommended serving size is varied in order to keep the number of servings per container constant, as is the case with single-serving canned soups, packets of instant oatmeal, or individual beverage boxes. Standardized serving sizes are needed so that information remains comparable within product categories, such as breakfast cereals, and across product categories. Alternatives to Serving Size Specifications If serving size is less than ideal as a reference standard, the alternatives need to be considered One alternative would be to declare nutrient content per pacl~ge or container and let consumers judge the proportion of that package that is being consumed at any eating occasion. Such a concept is useful for single-serving containers which are currently popular, but in the Committees view could make it very difficult for the consumer to relate the nutrition data to the amount actually consumed, especially for packages containing large numbers ~ . or servings. Another alternative would be to declare nutrient content per 100 g or other standard unit. This approach is used internationally where the metric system

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268 NUTRITION LABELING Using Food Label Information To Make Food Choices Consumers define the quality of a diet in terms of types of foods, not nutrients (Liefeld, 1983~. In order to facilitate dietary changes, consumers must understand the contributions that specific foods and food types make to the overall diet. From this perspective, science-derived diet and disease messages must be supplemented by information about the nutritional characteristics of specific foods and food types, and how to buy and prepare appropriate foods and meet appropriate quantitative goals. Without such understanding, attempts to modify dietary intake may not meet with success. From the perspective of helping consumers make intelligent food selections, one difficulty with diet and disease messages is that these messages usually are based on food components whose scientific role is not well understood by consumers. For most consumers, cholesterol, fatty acids, fiber, and sodium are relatively new terms when they are applied to making food choices. As a con- sequence, consumers may need to acquire knowledge about specific nutrients, food components, or food and nutrition processes in order to implement the generic dietary advice implied by such messages. To apply the general recom- mendations to reduce the intake of saturated fatty acids or sodium or to consume more dietary fiber, for example, an individual must understand the major food sources of these components, the contribution of different foods to the total diet, and how one's present diet may be excessive or deficient in these food comply nents. Appropriate dietary behavior depends on consumer's ability to recognize foods with desirable properties, to understand relevant terminology and apply it to food choices, to critically evaluate claims, and to assess the relative benefits of possible dietary changes in their own diets. Committee Recommendations The very concept of a comprehensive national nutrition policy suggests that not only should adequate supplies of safe, nutritious foods be available but that consumers should be given the educational means for making informed food choices (Helling, 1989; Quelch, 1977~. The Committee understands that a nutrition labeling program is only one component of a comprehensive education program, but believes that a well-designed nutrition label can help consumers to make informed food choices. However, nutrition information on food labels is just that, an information provision strategy, not an education program. The provision of information is only the first stage in the behavioral change process. Nutrition labeling can provide information about food and nutrition to the public, but it cannot be a substitute for comprehensive nutrition education programs. It is imperative that nutrition education programs be designed to complement nutrition labeling in order to give consumers the information and skills to make healthful food choices.

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PRESENTATION OF N~ION INFO~AHON ON FOOD ~~ 269 A comprehensive, coordinated program of nutrition education will enable consumers to make individual food choices within the context of their own comprehensive program for health maintenance and disease prevention. The Committee urges the establishment of a public- and private-sector initiative to better help consumers understand and apply the information on the revised nutrition label. However, the Committee refrains from providing a discussion of or recommendations about Be specific aspects of nutrition education programs in deference to the pending Institute of Medicine/~;NB report by the Committee on Dietary Guidelines Implementation which will address this subject in depth (IOM, in press). The Committee recommends that comprehensive nutrition education pro- grams be developed in order to assist consumers to understand the information on food labels to plan diets and make appropriate food choices. It is the re- sponsibility of those designing such public information programs to ensure that consumers can process the information easily and accurately. This means that more attention must be given to thorough message testing research to determine the most effective format for delivering nutrition information on food labels. 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 NUTRITION 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. It is not only the Committee's recommendations that would result in such costs; FDA's recent nutrition labeling proposal and the nutrition labeling legislation currently before Congress would impose similar costs. The Committee was not charged with assessing the costs of its or any other set of proposals for reform. But it would be irresponsible not to acknowledge that expanded and improved nutrition labeling will have costs and that the magnitude of these costs ought to be taken into account by FDA and USDA in their formulation of He details of and, even more important, the timing of a revised nutrition labeling system. In 1990, FDA commissioned a study on the costs of implementing the type of changes in nutrition labeling that it was planning to propose (55 ~d. Reg. 29,47~29,533; July 19, 1990~. The agency's notice of proposed rulemaking contains a preliminary analysis of the private-sector and consumer costs in

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270 NATION LABELING the first four areas of implementing revised nutrition labeling regulations: (1) extending mandatory nutrition labeling to all packaged foods, (2) standardizing serving sizes, (3) revising the U.S. RDAs, and (4) listing all optional ingredients in standardized foods. FDA estimated that 21,000 arms would be affected and that the cost per U.S. household will be $3.15 in the first year of implementation of its proposal, and $0.60 per U.S. household each year afterward. This estimate, if accurate, may provide some guide as to the costs of the Committee's more ambitious set of recommendations. The added costs of expanded nutrition labeling must be compared to the savings through improved health that consumers are expected to realize by having and using improved, more comprehensive nutrition information. The Committee believes that potential long-term savings in health care costs and gains in longevity would outweigh the cost of its recommendations. Overview of Costs To Manufacturers and Retailers The costs incurred by food producers will include those for administrative activities, nutrient analysis of foods, changes in label design, printing new labels, and in some instances, reduced ingredient flexibility. Within the first category are the costs of discovering and interpreting new requirements, assessing their impact on products, and developing a product compliance system. In addition, retail food stores, which under the Committee's proposal would be required to post nutrition information about produce, meat, poultry, and seafood, would incur costs in preparing and maintaining this information. Some costs, however, notably the costs of assembling the information about nutrient content, will be borne by the suppliers of fresh foods. Ultimately, most additional costs will be passed on to consumers. FDA noted in its proposal that a firm's costs for nutrient analysis would depend to a great extent on which and how many of its products currently carry nutrition labeling or have nutrient analysis data available (55 Fed. Reg. 29,47~29,533; July 19, 1990~. For foods that have not previously provided nutrition labeling, the start-up costs of obtaining the required information may be substantial. Costs for relabeling would include label design, printing, and inventory costs. The latter could be minimized by scheduling the effective date of new regulations to conform with the already-scheduled "uniform compliance dates" for incorporating other mandated label changes and by allowing existing label stocks to be exhausted. For some foods there could conceivably be costs associated with reduced flexibility in the choice of ingredients. The Committee recommends that man- ufacturers be allowed to continue to use "and/or" labeling for fats and oils, on the condition that the food label state the highest level of saturated fatty acids achievable by any combination of listed fats and oils. This approach should not constrict choice of fats and oils unless manufacturers, worried about disclosing

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PRESEl1T~ION OF NUTRITION INFORMATION ON FOOD LANDIS 271 high levels of saturated fatty acids, decide to curtail their use of some highly saturated fats or oils. But the associated product costs of such changes would be offset by direct nutritional benefits for consumers. FDA's proposal is designed to require more detailed listing of fatty acid content, which could curtail flexibility in formulation. By limiting the breakdown of fat components to saturate and unsaturated fatty acids, however, the agency expects that most manufacturers will be able to maintain sufficient flexibility in their selection of ingredients to minimize any increase in the cost of the final product. Costs for Different Food Categories Four major sectors of foods will be affected by the adoption of new requirements for nutrition labeling: (1) foods that currently carry nutrition labeling; (2) food that do not currently carry nutrition labeling but have been analyzed; (3) produce and fresh seafood under FDA jurisdiction, and fresh meat and poultry under USDA jurisdiction, and (4) restaurant foods. Under the Committee's recommendation (as well as FDA's proposal and proposed legislation), virtually all packaged foods would be required to bear nutrition labeling. In addition, foods now bearing nutrition labeling would be required to provide different information. Cost for Foods That Currently Carry Nutrition Labeling It is the Committee's judgment that its recommendations for the content of nutrition labels would require very little information that producers do not already possess. Possibly, the requirements that sodium and dietary fiber be listed will require reanalysis of some products. However, the requirements for listing the content of fat, fatty acids, protein, carbohydrates, vitamins, and minerals do not appear likely to demand new testing. For foods in this sector (now 60 percent of all packaged foods), the Committee's recommendations would mainly require changes in the presentation of information that manufacturers already have. The timing of the imposition of such requirements could affect the cost of compliance. If new labels had to be prepared and applied on a schedule that took no account of the normal, commercially driven evolution of food labels, or other government-mandated label changes, the extra cost could be substantial. But labels undergo relatively frequent changes, and FDA customarily establishes a"uniform compliance date" for all required label changes far in advance of the effective date. The Committee believes that recommended changes in nutrition labeling should be implemented on the same schedule already fixed for other mandated changes, which should allow ublizabon of old label stocks. USDA should also follow this same approach for implementing changes in nutrition labeling for meat and poultry products.

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272 NUTRITION LABELING Cost for Foods That Do Not Currently Carry Nutrition Labeling For foods that do not now bear nutrition labeling of any sort, additional costs will be incurred. It is likely that manufacturers do not currently have complete information about the nutrient content of some products. The cost of analysis of these foods may not be trivial, though adequate methods and laboratory resources are available to analyze, at a reasonable cost, virtually all packaged foods for all of the nutrition components that the Committee recommends. It is reported that many packaged foods that do not currently bear nutrition labeling have nonetheless been analyzed by their manufacturers (Daniel Padberg, Texas A&M University, personal communication, 19903. The growth in voluntary nutrition labeling over the past decade and the willingness of most sectors of the packaged-food industry to accept, and in many instances support, mandatory nutrition labeling suggests that these costs will not be significant. The costs of relabeling can be controlled in the same fashion as for foods that already bear nutrition labeling, by allowing reasonable lead time and schedules, coupled with the mandated label changes. Costs for Labeling Fresh Foods Produce and Seafood The Committee is recommending nutrition la- beling, broadly defined, for selected produce and fresh seafood. Retailers will incur modest costs in displaying and maintaining the required information, but the major costs are likely to occur in assembling the data base to support the required nutrient declarations. The Committee acknowledges that FDA may have to adjust the timing of its requirement for such information in light of the costs, and time required, to comply. The Committee recognizes, as does FDA, that providing point-of-purchase nutrition information for produce and fresh seafood will impose significant new costs on retailers and on consumers. Some 235,000 food stores were estimated to be in operation in 1987. FDA's proposal does not provide any estimate of total compliance costs. It does estimate that 50 percent of stores could supply the required information at an annual cost of $200 per store, but it acknowledges that this figure does not include the cost of generating the data bases to support such displays, and a portion of this cost is likely to be borne by food stores and, ultimately, consumers. Meat and Poudtry Unlike either the FDA proposal or pending legislation, which do not mention meat and poultry products, the Committee is recommend- ing nutrition labeling of all packaged meat and poultry products and point-of- purchase information for fresh meat and poultry products. A share of USDA- regulated packaged foods now bear nutrition information, and the abbreviated

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PRESE=~ION OF NUTRITION INFORMATION ON FOOD LABEl~; 273 USDA format demands less information than FDA, only requiring information about calories, protein, carbohydrate, and fat. Fresh meat and poultry do not provide significant amounts of dietary fiber. Analysis for sodium, calcium, and iron would be an expense only if they were not included in the original analysis. Costs for labeling fresh meat and poultry products would be from printing and maintaining point-of-purchase information in retail food stores, since the data would be taken from existing nutrient data bases. Broadly speaking, however, it would appear that the cost of implementing the Committee's recommenda- tions for meat and poultry should not differ substantially, on a per product basis, from those incurred by FDA-regulated packaged foods and for produce and fresh seafood. A caveat should be added here, however. It is possible that USDA's rigorous criteria for approving nutrient statements on the labels of meat and poultry products would impose higher per product costs than those of FDA. The deparUnent's prior approval system, like other premarket approval systems, appears to invite the Me of skepticism that drives up the cost of product testing. The Committee believes that it is important for FDA and USDA to agree on uniform criteria for assessing the accuracy of label statements of nutrition content as well as on consistent standards for approving data bases as the source of nutrient composition data for fresh foods (see Chapter 5~. Costsfor Obeying Restaurant Foods In one respect, the costs of the Committee's recommendations will differ sharply from those of FDA's proposal or the pending legislation. The Committee is recommending that limited-menu restaurants be required to display point- of-purchase nutrient content (and ingredient) information on Heir foods and that all other restaurants be required to have such information available to consumers on request. The first half of this recommendation is not likely to entail substantial additional costs, either for the limited-menu restaurant or for consumers. The products sold by these operations are standardized, carefully controlled for content and quality, and generally uniform throughout the country, and the world. Major limited-menu restaurant franchise chains have previously reported that they have already analyzed their products for nutrient content. The only significant new cost involved is likely to be that of preparing and maintaining the posted nutrient information. The recent willingness of several major chains to display information of the Me recommended by the Committee suggests that this expense is, on a per restaurant basis, modest. The costs of the Committee's recommendation to require all other restau- rants to have their menus evaluated and to offer nutrient information on request to consumers are considerably less ceItain and more speculative. The Committee believes that computer programs for evaluation of the nutrition profile of menus

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274 NUTRITION lW3ELING is widely available and inexpensive, but even modest expense may prove high for small operators (see Chapter 5). Printing the statement "nu~idon inforrnabon is available on request" on menus would be essentially costless. If requests were frequent, however, the cost of preparing, duplicating, and maintaining menu in- fonnation could prove more than trivial, particularly for operators Eat changed menus frequently. This is an area in which close study of potential costs is warranted. REFERENCES Asam, E.H., and L.P. Bucklin. 1973. Nutrition labeling for canned goods: A study of consumer response. J. Market. 37:32-37. Babcock M.J., and M.M. Murphy. 1973. Two nutrition labeling systems. J. Am. Diet Assoc. 62:15~161. Betteman, J.R. 1979. An Information Processing Theory of Consumer Choice. Addison- Wesley, Reading, Mass. 402 pp. Bettinghaus, E.P. 1986. Health promotion and the knowledge-attitude-behavior contin- uum. Preventive Med. 15:475-491. CNCFL (Committee on the Nutrition Components of Food Libeling). 1990. Workshop on Label Formats, CNCFL, Food and Nutrition Board, Institute of Medicine, April 25, 1990. Unpublished. Cole, C A., and GJ. Gaeth. 1990. Cognitive and age-related differences in the ability to use nutritional information in a complex environment. J. Market. Res. May:175- 184. CRI (Consumer Research Institute). 1972. Interim Report of the First Two Phases of the CRI/FDA Nutrition Labeling Research Program. CRI, Washington, D.C. 223 pp. Cronin, F.J., A.M. Shaw, S.M. Krebs-Smith, P.M. Marsland, and L. Light. 1987. Developing a food guidance system to implement the Dietary Guidelines. J. Nutr. Ed. 19(6):281-302. Daly, P.A. 1976. The response of consumers to nutrition labeling. J. Consumer Affairs 10(Winter): 170-178. DHEW/USDA/FI`C (U.S. Department of Health, Education, and Welfare, U.S. Depart- ment of Agriculture, and Federal Trade Commission). 1979. Food Labeling Back- ground Papers. Govemment Printing Office, Washington, D.C. 124 pp. DHHS (U.S. Department of Health and Human Services). 1988. The Surgeon General's Report on Nutrition and Health. Government Printing Office, Washington, D.C. 727 PP. DHHS (U.S. Department of Health and Human Services). 1989. Promoting Health/Pre- venting Disease: Year 2000 Objectives for the Nation. Draft for public review and commend Public Health Service, Washington, D.C. Eisner, D. 1972. Developmental relationships between held independence and Sxity- mobility. Perceptual Motor Skills 34(June):767-770. Farmakalidis, E. 1989. Nutrition labellingan industry perspective. Food Aust. 41~10~: 979-981. FLAPS Mod Libeling and Package Survey). 1988. Status of Nutrition and Sodium

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