Nutrient labeling of food products under consideration; position statement on food labeling

Nutrient labeling of food products under consideration; position statement on food labeling

Nutrient Labeling of Food Products under Consideration

We support a policy of providing sound nutrition information to the American public. It is clear that the amount of information the consumer needs far exceeds both the capacity of the lable to provide it and the capacity of the consumer to identify and assimilate it. Although the food label meets multiple societal and legal requirements, the nutrition label and other nutrition-related components of the food label should henceforth be viewed fundamentally as a tool for nutrition education. Substantial improvement in nutrition education of the public is necessary for food labeling to serve this purpose effectively. Both the label content and nutrition education efforts must be based on authoritative knowledge that has attained a reasonable degree of scientific consensus. The Dietary Guidelines for Americans published jointly by the Department of Health and Human Services and the U.S. Department of Agriculture are based on such consensus.

Specific recommendations:


1. The nutrition label or its equivalent should be available at the retail level for practically all foods.

2. The content per serving of energy, protein, total carbohydrate, total fat, saturated fat, cholesterol, sodium, calcium and iron should always be declared.

a. Energy should be listed as such, and quantitatively declared as Calories.

b. Carbohydrate should be the total of starch, sugars, polyols and dietary fiber.

c. Total fat should include triglycerides and polar lipids.

d. Saturated fat should include lauric (C12), myristic (C14), palmitic (C16) and stearic (C18) acids.

3. Optional nutrients and nutritionally related components may be declared, subject to certain provisions:

a. Vitamins and minerals should be quantitatively described on the basis of the most recent edition of the Recommended Dietary Allowances (RDAs), and must be declared if added.

b. Total sugars may be declared. If sugar-related claims are made, total sugars must be declared.

c. Total dietary fiber, and soluble and insoluble fibers, may be declared. In claims are made, they must be declared.

4. The health science base for fatty acids other than total and saturated fatty acids is insufficient at this time to make a meaningful declaration to consumers.

5. Exemptions from standard nutrition labeling (with provisions for other types of nutrition-related labeling as needed) are appropriate and should include: foods for infants and toddlers less than 2 years old; infant formulas; medical foods, dietary supplements; other specific foods for special dietary use. Nutrition labeling is unnecessary for spieces, flavors, artificial sweeteners, and other components of the food supply which make no significant contributions to nutrient intakes.

6. When the scientific consensus concerning the content of the nutrition label changes, an established procedure should permit easy modification of the nutrition label.


1. The AIN and ASCN have stated their opposition to disease specific claims on food labels and believe there is no scientific basis to change this position. Nevertheless, disease specific claims currently exist on some food labels. The Food and Drug Administration (FDA) proposal (Federal Register, Vol. 55, No. 30, 5176-5192, February 13, 1990) outlines a policy that would continue to permit disease specific claims on food labels. The challenge is how disease specific claims on food labels. The challenge is how disease the public trust.

2. The term “disease specific claims” is a more accurate description of the type of information addressed in the FDA proposal and therefore greatly preferable to “health messages.”

3. All disease specific label claims should be based upon critical evaluation of all available scientific evidence and should represent a reasonable degree of consensus within the scientific community.

4. All disease specific label claims should be accompanied by a comprehensive statement on the manner in which the specific food is to be used in the total diet.


1. For nutrients indigenous to food commodities and to commodity-based ingredients, mean values from data bases should be used for nutrition labeling whenever possible.

2. For food products formulated from commercially available ingredients, nutrient values for the finished products should be derived from nutrient values of the individual ingredients whenever possible.

3. Calculated levels of indigenous nutrients should be verified analytically for newly formulated or reformulated products, and should be confirmed periodically using statistically-based sampling plans.

4. Nutrients added for fortification should be analytically verified on an ongoing basis.

5. Criteria for assurance of validity of label claims for indigenous nutrients should be based on the variability of the nutrient in that class of foods. Criteria for such assurance for added nutrients should be based on the variability of accepted analytical assays.


1. Descriptors such as “low,” “reduced” and “free” for fat, saturated fat, and cholesterol should be defined. Similarly, definitions for vitamins and minerals interms of “good source” and “excellent source” are needed and should be based on current RDAs. In a like manner, definitions for total, soluble and insoluble fiber are also needed.

2. The limits of comparative claims for foods which do not meet categorical definitions should continue to be used and further refined (for components listed in 1 above).

3. Cholesterol and fatty acid claims should be permitted only when there is quantitative disclosure of both.

4. If a food meets the definition for an adjectival descriptor, it should be permitted to be labeled accordingly, regardless of other characteristics of the food.

5. It is inappropriate to develop pejorative definitions and require the label to bear such claims.

6. At present, the science information base is inadequate to develop accurate adjectival descriptors for: essential fatty acids; mono-unsaturated fatty acids; polyunsaturated fatty acids; and the omega-3 and omega-6 fatty acids.


1. Foods governed by standards of identity should bear complete ingredient statements.

2. The ingredient list should be introduced by the words: “From Most to Least.”

3. Major ingredients should be designated as such in descending order of predominance, followed by minor ingredients (less than 2% by weight) designated as such and not necessarily in descending order.

4. Total sugars should be listed as such in the proper order or predominance with individual sweeteners listed in parentheses.

5. So-called “and/or” labeling of fats and oils should be continued.

6. It is not appropriate to adopt a numbering system for food and color additives for labels, nor to require percentage ingredient labeling.


1. The current diversity of serving size declarations should be minimized by development of standardized and indicated serving sizes for common foods.

2. Consumer research will permit selection of the most understandable format for presentation of nutrition information on food labels. This includes both the physical structure of the label and means of expressing quantitative information.

3. Food composition data bases require significant further development to permit implementation of the recommendations outlined above. A means of publicly recognizing the suitability of specific data bases needs to be developed.

4. A means to best describe the nutritional merits of packaged entire meals which contribute to attaining the Dietary Guidelines for Americans should be

developed. At present such multi-component products would generally not qualify for use of adjectival descriptors developed primarily for individual foods. Similarily a means should be sought to describe the nutritional merits of restaurant meals and multi-component institutional packs.

5. An unresolved issue deserving attention is how to provide nutrition information about in-store processed foods and dishes “processed” by the consumer, e.g., at salad bars. This is a difficult problem because of wide variability in composition and nutrient content.

6. Consideration should be given to development of a type of abbreviated nutrition labeling for products packaged in small containers.

7. The entire national biomedical science and education communities need to focus on:

a. further development of dietary goals in quantitative terms;

b. further development of education programs in nutrition for school children and the general public–incorporating nutrition-related food labeling into the curricula.


1. Virtually all foods at the retail level should be nutrition labeled or its equivalent should be provided in some way.

2. Nutrition-related components of the food label are in need of substantive revision.

3. The nutrition label and other nutrition-related components of the food label should henceforth be viewed fundamentally as a major tool of nutrition education.

4. The identity and credibility of the nutrition label must be preserved.

5. Nutrition-related labeling should emphasize the total diet.

6. The research and developments needs identified in this report should be vigorously pursued.

7. The nutrition-related labeling and advertising policies of the Food and Drug Administration, the U.S. Department of Agriculture, and the Federal Trade Commission should be harmonized.

8. National uniform policies and regulations are essential to avoid chaos in nutrition education and in the provision of nutrition information.

COPYRIGHT 1990 Lippincott/Williams & Wilkins

COPYRIGHT 2004 Gale Group