While rather modest in size, the food label is a mighty piece of real estate. It is central to the conversation with consumers whether they are asking “what’s in it” or “what’s in it for me.”  It is closely watched by both regulators and advocacy.  It is a bully pulpit for food manufacturers as it’s used to share information and demonstrate they are listening to consumer wants, needs and preferences.

In 1990, the Food and Drug Administration (FDA) introduced the Nutrition Labeling Education Act, a guide for reviewing food labels for compliance with new requirements for nutrition labeling and nutrient claims.  In 1994, FDA defined the nutrient content claim “healthy” for use on food labels.  Today, FDA is seeking input in updating the definition of “healthy” and on March 9, 2017, held a public meeting to seek comments on the particulars of that update.

Needless to say, the job before FDA is neither simple nor straightforward.  Central to the discussion is the meaning of “healthy” which can vary from one consumer to the next.  Health is personal, and most consumers have personally defined what is healthy for themselves and their families as well as what is not.  While the claim “healthy” is a signal for consumers to incorporate into their overall consideration set when selecting individual foods, the goal is that the claim spurs a behavior change that will help consumers improve their diets overall.  “Healthy” also can be a catalyst for industry in innovating and renovating products.

Bottom line, the first order of business is understanding what “healthy” actually means to consumers.  Has its meaning shifted since the claim was first introduced?  Does it continue to motivate purchase, and does it do that more or less effectively than the “absent” claims that tout what is not in a particular food.  Values are an integral component of decision making concerning food choices, and many of the claims on-pack today appeal to a growing set of values concerning how food is produced and manufactured.  Does, for example, “no artificial preservatives” or “antibiotic free” translate to “healthy” in the minds of consumers today?  If so, the exploration of expectations for “healthy” among specific populations must be the first club out of the bag in efforts to redefine the claim.

Next, how does “healthy” work in concert with other on-pack claims, the Nutrition Facts Panel and the ingredient list.  We continue to hear less is more regarding ingredients, being able to pronounce and understand what’s in our food is paramount and level of processing is under increased scrutiny.  What story does that package tell and does it inspire the consumer to take action and action of what sort?  Specifically, does “healthy” trump other claims and/or nutrition information?  Is there additional context for “healthy” that needs to be available to the consumer on-pack or through other sources?

As the consumer is at the heart of this dialogue, the technical requirements for this update need to reflect what makes sense given where consumers are today.  Can “healthy” still work given the evolution of the conversation around food and nutrition, or is it now just old-fashioned?  There are many questions that will require careful navigation, including:

  • Will the updated “healthy” be food- or nutrient-based?  A hybrid seemed to be the preference at the March 9 public meeting.
  • How will a “meaningful” amount of food be defined?
  • The Nutrient Facts Panel addresses shortfall nutrients – are there unintended consequences to only reflecting those in “healthy?”
  • What will be the balance of foods to encourage versus foods to limit?  Certainly, the scale will tip in favor of foods to encourage, but how much and under what circumstances.
  • How will fortification be handled?
  • And, perhaps most important, what about calories?

The March 9 meeting discussion included perspectives reflecting every point on the spectrum from strict to not-so.   Now the research must be done to determine what will be useful for consumers, effective for industry and hit the bulls-eye for FDA to meet their public health responsibilities. At the end of the day, however, we must remember we’re all consumers – every single, individually-minded one of us.

Starting out as a high school English teacher, Mary Christ-Erwin learned to dig beneath the surface and stand her ground early on.  Now, leading Porter Novelli’s food, nutrition and policy work, Mary’s passion is burrowing into current and emerging issues, examining how they are impacting consumer and stakeholder mindsets, and then create relevant and effective positioning for clients.