The U.S. Food and Drug Administration (FDA) is updating the use of the term healthy on food labels for the first time since 1994. These changes attempt to align the agency’s definition of healthy with the latest nutrition science and federal dietary guidelines.
The word healthy, like the phrases low fat or good source of calcium, is an implied nutrient content claim, meaning it suggests that “a nutrient or an ingredient is absent or present in a certain amount,” according to the Code of Federal Regulations. When consumers see the term healthy on food packaging, they can assume the product supports federal dietary recommendations, as noted in the current rule.
If companies want to use the healthy claim, the product must abide by specific thresholds of total and saturated fat, cholesterol, and sodium, and contain nutrients like Vitamin A, calcium, or iron.
Uses of the label can be helpful for food products whose nutritional value is not as clear as, raw fruits and vegetables, according to Cydnee Bence, Attorney and Adjunct Professor at Vermont Law and Graduate School. “Where the term healthy does a lot of lifting is on foods that people may not just inherently trust are going to be healthy,” she tells Food Tank.
Under the current regulations, certain foods deemed healthy by the government’s own recommendations are not allowed to bear the word healthy on packaging. The FDA observes that salmon and olive oil, two examples of nutrient dense choices in the U.S. Department of Agriculture’s Dietary Guidelines, 2020-2025, are considered too high in total fat to be eligible for the healthy claim. Meanwhile, cereals, snacks, and other processed foods high in added sugar, yet low in fat and fortified with certain nutrients, may carry the claim.
“I could fill a whole cart with foods exclusively labeled as healthy and still not have a truly healthy complete diet,” Bence says.
The new proposed rules will address this issue by regulating healthy claims primarily according to food groups, as opposed to individual nutrients. Food products will need to contain a specific amount of food from at least one of six categories: fruits, vegetables, grains, dairy, proteins, and oils. The FDA also plans to continue limiting nutrients including sodium, saturated fat, and added sugars, with baseline amounts varying by food group. Additionally, the agency would remove minimum micronutrient requirements, preventing the labeling of unhealthy foods as healthy simply for containing a large amount of a single nutrient like calcium.
Through these changes the FDA acknowledges that “nutrients are not consumed in isolation” but rather in a broader “dietary pattern.” A dietary pattern refers to the food and beverages people regularly consume and the synergistic effects of those choices. According to the FDA, prioritizing a variety of food groups, rather than specific nutrients, is indicative of better health.
This shift toward food groups “more accurately reflects how consumers view their own food choices,” Bence tells Food Tank. But she has concerns that these new rules may allow too many “borderline foods” to be labeled healthy. Defining foods according to this food group criteria “expands that gray zone where there’s genuine conflicts within the nutritional space,” she says. For instance, dairy products are the subject of much debate by nutrition professionals and may or may not deserve the halo of the healthy claim.
These modified standards come shortly after the White House Conference on Hunger, Nutrition, and Health, which outlined the need for addressing high rates of diet-related disease in the United States. According to the FDA, more than 630,000 Americans die from heart disease and 600,000 die from cancer each year, while around 34 percent of adults have pre-diabetes. In light of these dietary and disease trends, the FDA recognizes the need to convey clear and accurate information on labels.
“If I’m going through the store, I spend about two seconds making a decision on what I’m going to buy,” Bence tells Food Tank. “[If] I see the term healthy…I’m just going to assume this is good for me,” she says, speaking to consumers’ reliance on labels to make informed choices.
However, the healthy claim is “not an endorsement by the government” and the FDA cannot ensure that “any individual consumer’s idea of healthy is going to align with what’s in these regulations,” Bence points out. “Healthy at the end of the day is still a marketing term.”
While the proposed rules may not address all the “inherent challenges with implied nutrient claims,” the existing framework is still “well overdue for an update,” Bence says. “Ultimately I think this is a move forward.”
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Photo courtesy of Ella Olsson, Unsplash