By Nicole Koch, Food Labeling Professional
A few months ago, the Food and Drug Administration (FDA) announced they are proposing changes to the claim “Healthy” on food labels. The regulations are being updated to match current dietary guidelines and the new nutrition facts panel. Since many Americans do not eat enough vegetables, fruit and dairy, the FDA wanted to encourage increased consumption of these food groups. In addition, most people consume too much added sugars, saturated fat, and sodium, so the FDA wanted to encourage limiting the amount of these nutrients in American’s diets. These changes align with current nutrition science.
Even though the comment period for the proposed rule Food Labeling: Nutrient Content Claims; Definition of Term “Healthy” closes on February 16, 2023, and we won’t know the final rule until the FDA has had time to analyze and incorporate the comments into the final rule, it is important to understand the proposed changes and the impact they might have on your food labeling.
The new definition of healthy
The new definition of “healthy” would be based on foods having a minimum amount of at least one of the recommended food groups and maximum amounts of Added Sugars, Sodium and Saturated Fat. The food groups included in the proposed rule are Vegetables, Fruits, Grains, Dairy, Proteins and Oil and the required minimum amounts of each are based on Food Group Equivalents. The food group equivalents and the three nutrients to limit were chosen based on recommendations in the Dietary Guidelines for Americans, 2020-25.
The proposed rule includes exceptions for some products. Raw, whole fruits and vegetables can use the claim “healthy” without meeting additional requirements. Pure still water and carbonated water can also use the claim without additional requirements if it is 100% water.
Food product categories
Under the proposed rule, food products are placed into the categories of Individual Foods or Combination Foods. Individual foods must meet a minimum amount of one food group and these minimum amounts are based on food group equivalents found in the Dietary Guidelines 2020-25. The nutrient limits for Added Sugars, Sodium and Saturated Fat all depend on the food group that the product contains.
Combination Foods are defined as foods comprised of meaningful amounts of more than one food group. This category contains Mixed Products, Main Dish Products, and Meal Products. In the proposed rule, products in this category contain more than one food group and must include minimum levels of food group equivalents based on the type of product. These foods have maximum allowed levels of Added Sugars, Sodium and Saturated Fat that are calculated using the nutrient limits of the food groups contained in the product.
A “Healthy” symbol
The FDA has stated they are researching a symbol that would represent the “Healthy” claim on food labels. They did not release additional information on what the symbol would be or the requirements for using it, but they did indicate they believe the updated definition of “healthy”, and a symbol would help consumers easily identify healthier food choices.
The FDA has yet to complete the full process before we know what the new rule will include. In the meantime, food companies need to comply with the current “healthy” requirements.
Some resources that might be of interest:
- Food Group Definitions and Individual Food Limits: download the PDF we put together with the food group definitions from the dietary guidelines and the limits for nutrients in individual foods.
- Food Labeling Online training: this course will help you understand how to apply FDA regulations to your entire package label.
- Labeling of FDA Food Products - Virtual Instructor Led Training: this virtual instructor led training will teach you how to develop your labeling correctly and be compliant with FDA requirements.
- AIB International’s Food Labeling Department: contact one of your experts if you need help calculating nutrition and creating ingredient statements for products or an expert opinion to evaluate the claims you want to make on your labels. Send an email to LabelOrder@AIBInternational.com.
