With increasing consumer awareness of nutrition, and the influence
of nutrients on dietary related diseases, the need for accurate and
standardization of nutrition labeling is apparent.
The eating habits of Americans have changed extensively since the
turn of the century. Changes have occurred in the composition of foods
because of improved production methods, new varieties, and advances in
food processing.
The primary changes in the past 70 years have been an increase in
the percentage contributed by fats, oils, sugars, and sweeteners and a
decrease in the percentage contributed by grain products. Although no
change has occurred in the amount of protein consumed, a greater
proportion now comes from animal sources. Dietary fiber is considerably
below the recommended level. In general, intakes of vitamins and
minerals are adequate in the United States today.
From a general marketing standpoint, it is readily apparent that
nutrition "sells" to today's consumer, making nutrition an integral
part of product development and promotion. Consumer feedback is a
powerful mechanism for manufacturers in developing new products that
provide the health and nutrition characteristics sought by the public.
Food marketers guard a product's front panel with fervour for the
purpose of promotion and competition, they oppose any labeling
proposals that threaten their control of this part of food packages.
Americans are increasingly aware of health risks associated with
sodium, fat, and cholesterol and report eating less salt, red meat,
butter, whole milk, and eggs.
Studies on the use of food labels reveal that consumers want
comprehensive nutrition information. About half of consumers report
that labels fail to provide all the information they desire and that
more information should be provided on caloric, fat, and sodium content.
Laboratory analysis provides quantitative nutrient information for
nutrition labeling of food products. Considerable improvement is needed
to validate and standardize analytical methods for use in nutrition
labeling. Particular problems exist in the measurement of dietary fiber
and many vitamins, and in databases used for foods for which direct
laboratory analysis is impractical.
If consumers are to make the dietary adjustments recommended by
health experts, they must be able to make informed choices in food
selection, preparation, and consumption. Although about half of
packaged foods currently carry nutrition labeling, the lack of relevant
and consistent information on all food products is a major deterrent to
consumers who wish to make informed choices.
The Committee on the Nutrition Components of Food Labeling, National
Academy of Sciences, Washington D.C., recommends that nutrition
labeling be made mandatory on most packaged foods. There is no longer a plausible excuse for packaged foods not to provide nutrient information.
Current dietary recommendations advise consumers to modify their
intake of certain food constituents. In considering those dietary
recommendations, the committee believed that more categories of food
should be required to carry nutrition labeling. That nutrition labeling
be provided at the point of purchase for produce, seafood, meats, and
poultry. In addition restaurants should make information on the
nutrient content of menu items available to consumers on request.
Growing public interest in nutrition has led manufacturers to
characterize their products as nutritionally beneficial through
widespread use of principal display descriptors; this practice has
drawn considerable attention from regulatory bodies and groups
concerned with health.
Despite the high popularity of terms such as "low-calorie", "fat
free", "no cholesterol", "fiber rich", and "lite", the potential for
confusion, exaggeration, and deception has prompted proposals that
these descriptors be prohibited. Although it may be truthful to label a
food "no cholesterol", that descriptor would mislead someone if the
food also contains substantial amounts of total fat and saturated fatty
acids.
Nutrition information on food labels is a mechanism to provide
information and facilitate behavior modification. The government should
allow the information to appear and regulate content, format, and
placement. Although information campaigns to promote health are
generally aimed at enhancing knowledge, changing attitudes, and
improving skills, changes in consumer knowledge and attitudes do not
directly result in adoption of health-promoting practices. Consumers
need information to make long-term dietary changes, yet more than just
information is necessary to achieve this goal.
Dietitians are the health professionals most involved in educating
consumers about the use of food labels in selecting foods to meet
dietary goals. Most diet-related health problems develop gradually,
without immediate or dramatic symptoms. Risk factor reduction and
disease prevention through dietary change require individuals to make
long-term and often arduous changes in food habits.
For the food industry, health professionals, and consumer groups, it
will be of interest in terms of their own objectives in promoting
nutrition labeling changes that are in line with current dietary
recommendations and in product development. [Earl, R., Porter,
D.V., Wellman, N.S., Nutrition labeling: Issues and directions for the
'90s. Institute of Medicine National Academy of Sciences. September
1990.]
The rules of labeling are set out by the Food and Drug
Administration (FDA). The following are excerpts from comments
presented to the Advisory Committee on the FDA's Subcommittee on Food
and Veterinary Medicine, on September 6, 1990, by Nancy S. Wellman,
PhD, RD, President of The American Dietetic Association.
FDA needs independence from politics, particularly in regard to
rulemaking. FDA autonomy is essential to its mission. It has been
dismaying for dietitians to see rulemaking proposals stalled and/or
overturned as has happened in the past for health claims, cholesterol,
and various food safety issues such as food colors. Food labeling is an
example where FDA suffers from the lack of overarching government-wide
policy. FDA must be allowed to make decisions independent of current
Administration bias.
Dietitians believe Americans want a stronger, yet reasonable FDA -
an FDA in tune with the times, an FDA with the autonomy to fulfill its
mandate. The FDA must take a more contemporary, broader role in not
only safeguarding, but improving the nutritional status of Americans.
RD's have seen FDA's stature diminish in the eyes of consumers
because food labeling reform is overdue. Labeling regulations have not
kept pace with contemporary food and nutrition science or with consumer
demand for more nutrition information. RD's use food labels in everyday
work as teaching tools to help consumers make life-saving or
life-lengthening food choices. RDs are, therefore, keenly aware of the
shortcomings of today's food labeling system.
FDA should use its range of legitimate justifications including
public safety, prevention of consumer confusion, and interstate
commerce concerns. No time resources should be devoted to determining
who has authority. Action should be the goal.
A comprehensive nutrition education program will be needed to
educate consumers regarding the availability and appropriate use of
improved food labeling. FDA should work to maximize the impact of food
labeling reform on the nutritional status of Americans. A strong
commitment to nutrition education through resource allocation and
advocacy by FDA is essential. [Journal of American Dietetic Assoc. 90:1522. 1990.]
Food Labeling Legislation
The Nutrition Labeling and Education Act of 1989, was the main food
labeling bill in the 101st Congress. The House passed it and the Senate
passed the same bill with some minor amendments.
The legislation includes the following:-
Mandatory labeling is required for most foods under the
jurisdiction of the Food and Drug Administration but not those covered
by the US Department of Agriculture (i.e.. meat and poultry). The label
would include:
- Serving size, in standard, common household measures
- Number of servings per container
- Total calories
- Total fat, saturated fat
- Cholesterol
- Sodium
- Total carbohydrates, complex carbohydrates, and sugar
- Total protein, and
- Dietary fiber.
voluntary nutrition guidelines for fruits, vegetables and raw fish. The
guidelines will apply to 20 varieties of vegetables, fruit and raw fish
most frequently consumed during a year, and the secretary will decide
which foods will come under this requirement.
formula, foods with insignificant amounts of the nutrients required to
be listed on the label, such as spices, and some other minor exemptions.
It also addresses the issue of claims that may be made
about the nutrients in the food. First, content claims, such as "low
salt", or "light" would have to be consistent with terms defined by the
Secretary. Second, there would be a process for the orderly regulation
of disease claims such as "fiber. prevents cancer". FDA would review
the scientific evidence and decide whether a claim is valid. A disease
claim may not be made unless it is consistent with a final regulation
issued by the FDA. Also, a claim may not be made if it is misleading in
light of the level of another nutrient in the food; it must be based on
the totality of scientific evidence on which there is significant
scientific agreement.
[Legislative Highlights. JADA. 90:1653. December 1990.]
Cholesterol Labeling Rule
The Food and Drug Administration's final rule on Food Labeling:
Definitions of the terms Cholesterol Free, Low Cholesterol, and Reduced
Cholesterol, were published in the July 19, 1990, Federal Register.
Cholesterol Free:
- Less than 2 mg of cholesterol per serving; and
- 5 gram or less total fat per serving; and
- 20% or less total fat on dry weight basis; and
- 2 gram or less saturated fatty acids per serving; and
- 6% or less saturated fatty acids on a dry weight basis.
Low Cholesterol:
- 20 mg or less cholesterol per serving; and
- 0.2 mg or less cholesterol per gram food; and
- 5 gram or less total fat per serving; and
- 20% or less total fat on dry weight basis; and
- 2 gram or less saturated fatty acids per serving; and
- 6% or less saturated fatty acids on a dry weight basis.
Reduced Cholesterol:
The American Dietetic Association (ADA) believes that the descriptor
"reduced cholesterol" should be removed from this regulation as it
would be misleading to the consumer. The average consumer could read
the "reduced cholesterol" label and think that, like the other terms
used for cholesterol, it also applies to foods allowed in a diet to
reduce serum cholesterol. The positive consumer impact from the use of
this term is negligible.
If this term is to be kept in the regulations, ADA believes its use
should definitely be conditioned to specific levels of total fat and
saturated fat. The purpose of this rule is to protect the consumer from
misleading food labels. If consumers are encouraged to reduce their
cholesterol intake, but not told to reduce their intake of total fat
and saturated fat, the first advice would be useless. FDA needs to be
consistent in its application of cholesterol terminology.
Comparative claims:
The ADA endorses FDA's decision not to allow terms such as "lowered"
and "less" as food descriptors for foods with a 25 percent or more
reduction of cholesterol. These terms can only be used in comparative
statements. Comparative claims should also be conditioned to specific
levels of total fat and saturated fat to maintain consistency in
cholesterol terminology.
Consumers need to learn to make comparisons among food products when
making purchasing decisions. Allowing manufacturers to make cholesterol
comparisons on labels would benefit consumers. [Legislative Highlights: ADA's response to FDA's cholesterol labeling rule. Journal of ADA. 90:1520. 1990.]
Fatty Acid Declaration
The FDA requires that saturated and unsaturated fatty acids be
declared in nutrition labeling whenever cholesterol information is
provided, regardless of whether a cholesterol claim is made on the
principal display panel. This is necessary to prevent consumer
deception.
Omega-3 and Omega-6 Fatty Acids:
Voluntary differentiation of polyunsaturates into omega-3 or omega-6
fatty acids is not allowed. There has been little research done in this
area and it would have the potential for confusing the consumer.
