The goal of the proposed FDA Nutrition Facts Label changes is to provide improved information to consumers so that they may better maintain healthy dietary practices. The shift will affect consumers directly by providing updated information on portion sizes and dietary recommendations, while offering an improved design that makes the relevant information more prominent. As a result, however, food manufacturers will have to consider whether or not to reformulate their products in order to maintain health and nutrient content claims and make products more attractive to consumers. The proposed changes that specifically impact the decision to reformulate are outlined below.
1. Changes in Daily Values
In the proposed regulations, the Daily Values (dietary recommendations) have been assessed and revised to reflect the latest scientific evidence. Due to these changes, current formulations will not reflect the same level of adequacy as before.
For example, manufacturers who currently fortify their products with 100% of the Daily Value of Vitamin B-12 will have a Daily Value of 250% if they continue to fortify at the same level. Manufacturers of ready-to-eat breakfast cereals often fortify their products to the 100% level, and consumers may not view a higher percentage in a positive light, causing more incentive to reformulate.
2. Changes in Portion Sizes
The guidelines for portion size regulation in the Recommended Amounts Customarily Consumed (RACC) have been updated to reflect the larger portion sizes that Americans commonly consume. This change could affect products that currently report health or nutrient content claims, since these claims are based on the RACC. If after a change in RACC the product is no longer able to make the previously reported health or nutrient content claims, the manufacturer would either need to remove the claim from the product label or reformulate to continue making the claim.
For example, currently a low fat ice cream with 3 grams of fat per ½ cup serving is eligible to make a low fat claim on the product. The proposed rules would double the RACC for ice cream from ½ cup to 1 cup. This increase in portion size would double the fat content from 3 to 6 grams of fat per RACC, making the product ineligible to keep the low fat claim.
3. Changes in the Definition of Dietary Fiber
The new labeling regulations will also require a new definition of “dietary fiber”. The new definition counts dietary fiber that has a physiological effect that is beneficial to human health and excludes both soluble and insoluble non-digestible carbohydrates. This change could affect products that make fiber claims but include fiber that does not meet the new definition.
For example, currently a breakfast bar that contains 6 grams of dietary fiber per 40 gram bar can claim “excellent source of fiber” on the product package. If the source of fiber, however, is from an isolated/synthetic fiber that does not meet the new definition, the manufacturer would either need to reformulate with a fiber that meets the new definition, or remove the claim from the product package.
4. Making Added Sugars a Mandatory Label Nutrient
Proponents of the food industry may be motivated to reformulate by the increased visibility of added sugars. Added sugars are defined as calorie sweeteners that are either packaged as such or added during the processing of foods. As discussed in a previous blog post, added sugars are generally something that should be consumed in moderation. Thus, manufacturers may choose to reformulate their products if their current recipes report an amount that seems high.
For example, currently a fruit drink that contains 25 grams of sugar, including 15 grams of added sugar, only reports 25 grams of total sugar on the nutrition label. With the new added sugar rule, the drink would report 25 grams of total sugar and 15 grams of added sugar.
What’s A Food Manufacturer To Do?
The proposed nutrition labeling regulations provide challenges and opportunities for the industry. Manufacturers can stay ahead of the curve by using a nutrition labeling software that can produce government compliant food labels.