Redefining the Term “Healthy” on Food Packages – Public Process Plays a Crucial Role

By: Susan Mayne, Ph.D., and Douglas Balentine, Ph.D.

When you see the word “healthy” used on a food package, what does that mean to you?

Susan Mayne

Susan Mayne, Ph.D., is Director of FDA’s Center for Food Safety and Applied Nutrition

It’s FDA’s job to make sure that terms like “healthy,” which many people rely on to make food choices for themselves and their families, are something that they can truly count on. And we’ve seen that the ability to include the claim “healthy” actually encourages food companies to produce healthier foods. Back in the 1990s, the agency used the best nutritional science available at that time to define what “healthy” meant. And so, over the past two decades, food packages could be labeled as healthy if they met certain criteria for the content of fat, saturated fat, sodium and cholesterol and contained certain minimum amounts of nutrients like vitamins and minerals.

But nutrition science has evolved. Whereas in the past we placed greater emphasis on total fat, we now know that not all fats are alike, and some are better for health than others.  And while the focus on ensuring that people are getting the right amounts of different nutrients still matters, other things matter as well, such as food groups or the combinations of different foods and beverages in the diet.

Doug Balentine

Douglas Balentine, Ph.D., is director of the Office of Nutrition and Food Labeling at FDA’s Center for Food Safety and Applied Nutrition

So the question is: Can FDA update the definition of “healthy” in a way that makes sense and reflects our most current understanding of nutrition science today? FDA’s answer is: We want to do that, and we want the public’s help to make sure we get it right.  We want to hear from food companies that make and market food, from experts who study nutrition, and from consumers who, after all, are the ones to whom “healthy” claims are directed.

That goal prompted us to hold a public meeting in March 2017 on the term “healthy” on food labels, and we were delighted that hundreds of participants joined in person or via webcast. But if we were looking for an easy answer and widespread agreement on the definition of healthy, we didn’t find it there! The range of opinions we heard underscores just how complex the process of revising the definition will be.

Let’s take, for example, the different views of four participants in a panel discussion on stakeholder perspectives.

  • Kind Snacks, which has petitioned FDA to change its “healthy” definition, proposed, in part, that foods be defined as healthy if they contain a “meaningful amount” of foods that comprise a healthy diet and that don’t contain low- or no-calorie sweeteners or synthetic colors.
  • ConAgra Foods presented a framework for defining “healthy” by ranking foods based on their nutritional makeup, an approach that permits greater flexibility. If higher amounts of “food groups to encourage” are present, then there is some room for a food to be listed as healthy even if there are some “nutrients to limit” as well.
  • The Center for Science in the Public Interest said that a “healthy label” shouldn’t be a marketing tool that helps marginally better processed foods compete with fruits, vegetables and other truly healthy foods.
  • And the Academy of Nutrition and Dietetics, after talking to its members, said it could not come up with a good definition for “healthy” that FDA should adopt.

There were different opinions on whether we should continue to define “healthy” based solely on specific nutrients that are considered to play a role in lowering the risk of chronic disease. In that regard, some favored having the new definition continue to include certain beneficial nutrients, such as vitamins, minerals and fat. Others suggested it be based instead on beneficial food groups to – such as whole grains, fruits and vegetables – while still others opted for a combination of the two.

Participants also urged us to consider the goal of redefining “healthy” before deciding the criteria. Is the term primarily an educational tool? If so, then we must be transparent about what the term means because people view the word healthy differently depending on their perspectives and values. Alternatively, is the definition intended to be a guideline for industry in making claims about their products, or, is it a way to spur product reformulation towards healthier foods?

We welcome the diversity of comments we received – they will be added to the nearly 900 we’ve received from the public since September 28, 2016 when we published a Request for Information on the word “healthy.” To give the public time additional time to comment after last month’s meeting, we are extending the comment period until April 26.

We will study the comments carefully as we consider how to move forward, knowing it will be a challenging task, given the diversity of opinions, as the public meeting demonstrated. But the meeting also showed that an updated, and appropriate, definition of healthy is important to the American people, industry, health care professionals, food scientists, and other experts. Towards that end, FDA is committed to continuing this important dialogue.

Susan Mayne, Ph.D., is director of FDA’s Center for Food Safety and Applied Nutrition

Douglas Balentine, Ph.D., is director of the Office of Nutrition and Food Labeling FDA’s Center for Food Safety and Applied Nutrition

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