Would mandatory front-of-pack nutrition labels or a symbol to designate a food as ‘Healthy,’ help curb the incidence of diet-related chronic diseases? Academic and industry research has shown that nutrition information on the front of food packages is more commonly viewed by American adult consumers than the Nutrition Facts panel, which is placed on the side or back of a package. The increased viewing of nutrition information is associated with healthier dietary patterns. While several countries are advancing regulations for front-of-pack (FOP) nutrition labeling schemes, the future of a mandatory FOP system in the U.S. remains uncertain.

Diet and nutrition are closely linked to public health. In the United States, nearly half of all adults are estimated to have a preventable chronic disease associated with poor nutrition, such as type 2 diabetes, high blood pressure or cardiovascular disease; and more than two-thirds of adults are overweight or obese.

Due to the rising rates of diet-related chronic diseases and obesity in Mexico and Canada, both countries are considering mandatory FOP labeling comprised of colors, shapes and symbols to communicate health risks to consumers. Recently, Health Canada proposed a FOP labeling scheme to alert consumers of food products that are high in salt, sugar or saturated fat.

In contrast, the U.S. federal agency responsible for renegotiating the North American Free Trade Agreement (NAFTA) wants to block the implementation of mandatory FOP labeling rules within Canada and Mexico as part of the revised trade deal. According to recent news reports, the Office of the United States Trade Representative is seeking to prevent the use of any warning symbol, shape or color on packaging that suggests health hazards are associated with any food or non-alcoholic beverage.

FOP Labeling in the U.S.

A regulatory approach to FOP labeling has been under consideration in the U.S. for years, but the Food and Drug Administration (FDA) currently permits voluntary FOP labeling schemes such as the ‘Facts Up Front’ system developed by the Grocery Manufacturers Association (GMA) and the Food Marketing Institute (FMI). The Facts Up Front labeling scheme highlights key information from the Nutrition Facts panel, including certain nutrients and calorie counts.

Rather than voluntary industry FOP labels, the Institute of Medicine (IOM) suggested implementing a single, standard symbol labeling scheme for all food products, which would be utilized to translate information from the Nutrition Facts Panel. The IOM advised the FDA and USDA to develop a standard FOP system that would “motivate food and beverage companies to reformulate their products to be healthier and encourage food retailers to prominently display products that meet this standard.”  An IOM report provided recommendations for a FOP labeling system to highlight calories, saturated and trans fats, sodium and added sugars.  

Critics of industry labeling programs have suggested the FOP label simply serves as a marketing tool that highlights only positive values from the Nutrition Facts label. Nutrition experts Marion Nestle, Ph.D., MPH and David S. Ludwig, MD, Ph.D. were critical of front-of-package food labeling within a commentary published in the Journal of the American Medical Association (JAMA). According to the authors, the labels are misleading since very few of the health claims are verified, and the claims chosen to emphasize individual factors can ignore “potentially unhealthful aspects” of a food product.

Recent Developments

Currently, more than 20 countries permit some form of FOP label on pre-packaged foods to highlight certain nutritional attributes, including four countries in Latin America. In 2016, Chile implemented a labeling law that requires the use of a stop sign symbol on the label of all packaged foods containing high levels of sugar, calories, sodium or saturated fats. Canada, Mexico and Brazil are a few of the countries currently considering the implementation of nutrition warning labels similar to Chile, which emphasize the use of colors and symbols over quantitative values.

Health Canada is developing FOP labeling rules that will require food manufacturers to use approved symbols to alert consumers of high levels of sugars, sodium or saturated fat. Under the proposal, food manufacturers must utilize symbols approved by Health Canada when a product contains a high amount of any of the three nutrients of concern. The warning would be required if a product has 15% or more of the recommended daily value in prepackaged foods and 30% or more in prepackaged meals.

Health Canada will accept public comments on the proposed regulation, including opinions on which symbol to use, until April 26, 2018. As proposed, the compliance date for the Canadian FOP requirement would be aligned with the transition period for the 2016 nutrition labeling regulation, and the end date for both regulations would be December 14, 2022.  

Mexico’s Ministry of Health and the World Health Organization support FOP labeling regulations to aid public health efforts aimed at combating chronic diseases, particularly diabetes. To date, Mexico has not yet proposed labeling regulations to mandate the use of symbols to warn consumers of foods high in sugar, fat or salt.  

FDA’s Nutrition Strategy

The FDA recently unveiled a Nutrition Innovation Strategy to rekindle its past efforts on preventing chronic diseases linked to diet and nutrition. During the National Food Policy Conference last month, FDA Commissioner Scott Gottlieb stated that the agency will ask the food industry to reduce the amount of sodium in processed foods. The agency previously proposed voluntary draft targets for sodium reduction in foods, but the FDA will release official updated short-term targets for sodium in 2019.

While the FDA’s nutrition strategy omitted FOP labeling, the new strategy revealed plans to define “healthy” foods and to establish a ‘Healthy’ symbol for packaged food labels. The agency also suggested the healthy claim is “ripe for change.” In the future, we could see the FDA  expand the definition of healthy beyond nutrients to encompass dietary patterns and food groups such as whole grains, low-fat dairy, fruits and vegetables.

Academic and industry researchers have demonstrated the potential benefit of FOP labeling for improving the dietary choices of adults, but nutrition experts have expressed mixed opinions. If Canada and Mexico implement mandatory FOP labeling systems, the lack of a standardized labeling scheme within North America could hinder trade as well as challenge efforts to improve public health through proper nutrition.

Are your food labels up-to-date and compliant with the most recent regulations? Mérieux NutriSciences offers complete nutrition labeling options and food label review services to meet U.S. and Canadian regulations. Our Food Labeling Compliance experts can review specific aspects of your food label, such as the statement of identity, ingredient list, allergen declaration, or the entire label, including claims and font size. These services are not limited to the Nutrition Facts label; they extend to all mandatory elements of the food label packaging. Protect your company from a recall due to mislabeling and get started with your label review today!

Meet the Author

Patrick Kennedy
Information Services Manager, Mérieux NutriSciences

Patrick Kennedy is the Information Services Manager for Mérieux NutriSciences. He has over 15 years of food industry experience and has written extensively covering a wide range of food safety and regulatory subjects. He holds a MS degree in information science from the University of Illinois, and is a member of several industry organizations including AOAC, IFT and IAFP.

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