Nutrition Food Labeling Notes

Food Labeling Regulation

Fair Packaging and Labeling Act (1966)

• Motivated by public concern regarding the contents of processed foods.
• Established four mandatory elements on every food label:
  • Back Panel - Ingredient Statement: A comprehensive list of all ingredients in descending order by weight (highest to lowest).
  • Back Panel - Manufacturer Information: Name and address of the manufacturer.
  • Front Panel - Standard of Identity: The common or usual name of the food.
  • Front Panel - Net Weight: Net weight of the product in both ounces (Imperial) and grams (Metric).

First Nutrition Labels (1973 FDA Regulation)

• Mandatory if:
  • A nutritional claim was made on the label or in advertising.
  • Nutrients were added to a food product.
• Driven by growing scientific knowledge linking health and diet, and increasing consumer demand for nutritional information.

Nutrition Labeling and Education Act (NLEA) of 1990

• Granted the FDA the authority to mandate:
  • Mandatory nutrient labeling on most foods.
  • Voluntary nutrient labeling for raw fruits, vegetables, and fish.
• FSIS (Food Safety and Inspection Service) proposed mandatory labeling for meat and poultry products in 1991.
• 1994: Mandatory labeling requirements took effect for both FDA and USDA regulated products.
• Allowed claims linking a nutrient or food to a disease.
• Implemented standardized formatting for all nutrition labels.

Further Updates to Labels

• 2003: FDA finalized a ruling requiring the listing of Trans Fats on all food labels by 2006.
  • This was based on epidemiological studies linking trans fat intake to heart disease.
  • Trans fats increase LDL ("bad") cholesterol and decrease HDL ("good") cholesterol.
  • Trans fats are primarily found in partially hydrogenated oils, formed during the hydrogenation process.
• 2016: FDA revised the Nutrient Facts Panel to enhance clarity and provide more relevant information to consumers.
  • The mandatory compliance date for all labels to be updated was January 1, 2020, with extensions granted to small businesses.

Quick Guide to the Updated Nutrition Facts Label

1. Start Here: Focus on serving size, servings per container, and calories.
2. Check Calories: Observe the calories per serving.
3. Limit These Nutrients: Pay attention to the % Daily Value (DV) for total fat, saturated fat, trans fat, cholesterol, and sodium.
   • 5% DV or less is considered low.
4. Get Enough of These Nutrients: Focus on Vitamin D, calcium, iron, and potassium.
   • 20% DV or more is considered high.
5. Footnote: Explains the % Daily Value (DV) and its contribution to a 2,000-calorie diet for general nutrition advice.

2016 Label Updates

• Added Sugars:
  • Mandatory declaration of "added sugars," which include sugars and syrups added during processing or preparation.
  • This excludes naturally occurring sugars found in milk and fruits.
• Calories from Fat:
  • "Calories from fat" information was removed.
• Nutrients to Declare:
  • Revised nutrient list: Vitamins A, C, Calcium, and Iron were replaced by Vitamin D, Calcium, Iron, and Potassium.
• Updated Daily Values:
  • Daily values were updated based on the latest scientific evidence.
• Updated Serving Sizes:
  • Serving sizes were updated to reflect amounts people customarily consume (Reference Amount Customarily Consumed - RACC).
  • Some products previously labeled as >1 serving will now be labeled as 1 serving.

% Daily Value (DV)

• The % Daily Value (DV) represents the percentage of the Daily Reference Value (DRV) or Recommended Daily Intake (RDI) of a particular nutrient present in a serving of food.
• An RDI (for micronutrients) or DRV (for macronutrients) signifies the daily intake level of a nutrient that meets the requirements of 97-98% of healthy individuals in the U.S.
• Based on a 2,000 calorie diet.

Daily Values for New Labels (Effective 1/1/2020)

Packages with Less Than 4 Servings

• Must include nutrition facts for the whole package, presenting values both per serving and per container (dual column).

New Serving Size

• Package size influences consumption patterns.
• For example, both 12 and 20-ounce bottles are now considered a single serving, reflecting typical consumption habits.

FALCPA (Food Allergen Labeling and Consumer Protection Act)

• Applies to packaged foods regulated by the FDA, including both domestically manufactured and imported foods.
• Excludes meat, poultry, and egg products regulated by the USDA's Food Safety and Inspection Service (FSIS).

Gluten Labeling

• Part of FALCPA.
• To be labeled "gluten-free", products must contain less than 20 parts per million (ppm) of gluten.
• Allowable label statements:
  • Gluten-Free
  • Free of Gluten
  • No Gluten
  • Without Gluten
• Ingredients derived from gluten-containing grains can be labeled as gluten-free if processed to remove gluten.
• Celiac Disease:
  • Estimated to affect 1% of the population worldwide.
  • Autoimmune disorder with a genetic predisposition.
  • Causes damage to the lining of the small intestine.

USDA’s FSIS Practices

• Promote accurate and informative product labeling.
• Allow voluntary label statements to alert individuals with allergies to specific ingredients. Examples include "Contains: milk, wheat, soy".
• Encourage clarification of ingredient sources: e.g., "whey (from milk)", to provide consumers with recognizable terms.

"Contains" vs. "May Contain"

• "Contains" indicates that the ingredient is present in the product.
• "May Contain" is a voluntary statement used when there is a potential for allergen cross-contamination during manufacturing.

Three Types of FDA Claims for Foods

1. Nutrient Content Claims:
   • Describe the level of a nutrient or dietary substance in a food product.
   • Examples:
     • Nutrients to Include:
       • More Calcium: 10% or more of the DV
       • Good Source of Calcium: 10-19% of the DV
       • High in Calcium: 20% or more of the DV
     • Nutrients to Limit:
       • Fat-Free: Less than 0.5 gram of fat
       • Low Fat: Less than 3 grams of fat
     • Comparison to a Reference Product:
       • Reduced or Less Fat: 25% less fat
       • Light/Lite in Fat: 50% less fat
2. Structure/Function Claims:
   • Describe the role of a nutrient or dietary ingredient and its effect on the normal structure or function of the body.
   • Examples:
     • Calcium builds strong bones.
     • Fiber promotes bowel regularity.
   • These claims do not require FDA pre-approval but must be truthful.
   • Structure/function claims cannot imply disease treatment or prevention.
3. Health Claims:
   • Describe the relationship between a nutrient or dietary ingredient and the reduced risk of a disease or disease-related condition.
     • Unqualified Health Claims:
       • Supported by ‘significant scientific agreement’ and do not require a qualifying statement on the label.
     • Qualified Health Claims:
       • Supported by scientific evidence, but not backed by 'significant scientific agreement'.
       • Must include a qualifying statement.

Levels of Qualifying Substances for Health Claims

1. Must contain at least 10% DV of the nutrient.
2. Foods with health claims must contain 20% or less of the DV of:
   • Total Fat
   • Saturated Fat
   • Cholesterol
   • Sodium
3. Cannot make a claim for a nutrient or ingredient that does not have a Daily Value (e.g., omega-3 fatty acids, as no DV is set).

"Healthy" Labels

• According to the FDA, foods labeled as "healthy" must be:
  • Low in fat, saturated fat, cholesterol, and sodium.
  • Contain at least 10% of the recommended daily value of Vitamin A, Vitamin C, iron, calcium, protein, or fiber.