After noticing an overwhelming response to our recent blog post on the Food and Drug Administration’s (FDA) review of Food Package Labels, we decided to take the next step and submit our own comments to the FDA. Keep reading for the text that we submitted this week (Comment Tracking Number: 80b19fb4).
We’d like to reiterate that the FDA is only looking at changing regulations that affect the front of a food package – not the Nutrition Facts Panel or ingredient statement. You’ll notice that our suggestions to the FDA reflect many of the ideas you expressed in your blog comments, but deal only with this aspect of food labeling. While we agree that issues such as labeling foods with ingredients from genetically-modified seed, removing the trans fat threshold loophole, and disclosing country of origin require attention from the FDA, this particular docket does not request commentary on these issues.
If you’d like to have your voice heard as well, you have until July 28th to share your thoughts with the FDA.
Comments in response to Docket ID FDA-2010-N-0210 (Front-of-Pack and Shelf Tag Nutrition Symbols)
July 14th, 2010
Based on the comments submitted to the GoodGuide.com blog and user preferences ascertained from website metrics, we would like to share the following comments and suggestions for consideration by the FDA.
There is general consensus that more information is required for the consumer to make an informed decision about food products. The information provided must be perceived as accurate and trustworthy. It should also be noted that omission of information can be misleading to consumers. Currently, there are consumers who disregard health claims on food packaging because they do not feel these claims accurately represent the benefits of the product bearing the claim. However, excess information is unlikely to help the average consumer choose healthfully.
We believe that improving point-of-purchase information in a reliable, trustworthy way will change consumer habits in a healthful way. As a result, food manufacturers may be encouraged to reformulate products in order to meet consumer demand. If manufacturers are not required to disclose in more detail or be more honest with labeling, consumers will continue to be misinformed and demand will not change.
In terms of specific suggestions, we provide the following thoughts for the committee to consider:
First, any federally regulated front-of-package information should weigh the demands of ease of use versus providing detail. As this information is likely to be used at the point of purchase, it will be more useful to use a simple, straightforward tool that does not require significant effort to interpret. Additionally, given that nutrition knowledge is not widespread, it is important to avoid technical jargon.
Second, ideally, whatever information is provided on the front of the package should be comprehensive in nature. To elaborate, labeling schemes should be a one-stop shop for information about the overall health impact of a product. The current regulation allows for nutrient content and health claims that focus on individual nutrients. Use of these claims has had the unintended consequence of consumers assuming that products have a “health halo.” Often times, when one nutrient is highlighted, other attributes of a product are not acknowledged by the consumer. For example, a product that bears the “low fat” claim may be high in added sugars, and therefore not a healthful choice. This loophole results in misinterpretation and should be anticipated during the development phase of this project.
Finally, in the absence of a new labeling scheme for the front of a food package, the FDA should consider moving the Nutrition Facts Panel and ingredient statement to the front of the package. By making this information more readily available, consumers are more likely to incorporate it into their purchasing decision. Coupled with label reading education, this action may help individuals make healthier food choices.
About GoodGuide: Our company provides consumers with information on the health, environment, and social impacts of products and companies, with the ultimate goal of helping individuals find safe, healthy, and green products that are better for themselves and the planet.