April 3, 2018

FDA Contemplates: What Makes a Food Healthy?

In September 2016, the FDA embarked on a landmark effort to revise the definition of “healthy” – an implied nutrient content claim popular on-pack and in advertising. Prompted by Kind LLC’s Citizen Petition, FDA sought to better align the claim with current scientific understanding and the Dietary Guidelines for Americans (DGA).

In 2017, FDA collected public input on claim revisions via a Request for Information that garnered more than 1,100 comments and in a public meeting attended by more than 200 participants.

Following that March 9 public meeting, the FDA acknowledged in a blog post the incredible diversity of stakeholder views in the complexity of the challenge ahead.

To gauge public opinion and predict the FDA’s potential direction, FoodMinds analyzed 53 letters from key opinion leaders, a sample of the 1,139 comments submitted¹. This analysis revealed four key themes:

What’s next?

A few months ago, most pundits anticipated that the likelihood of FDA advancing “healthy” regulations during the current presidential administration was slim. FDA’s newly published 2018 Strategic Policy Roadmap suggests otherwise. A final regulation on “healthy” could still be over a year away, but FDA Commissioner Scott Gottlieb announced in early February that he will deliver a speech in “a month or two” revealing more details.

What does this mean for your business? Beyond “healthy,” other nutrient content and health claims are due for an update – most haven’t changed since the 1990s. What FDA does with “healthy” could set a new paradigm for U.S. labeling. Business leaders should start preparing now for major marketplace changes. Consider taking the following actions:

¹FoodMinds selected the sample of 53 comments letters based on our expert knowledge of food and nutrition affairs. The sample was intended to represent leading voices (based on historic engagement in nutrition policy) across various stakeholder segments, including public health, academia, consumer advocacy, professional membership associations, and consumer packaged goods companies. The sample was not intended to reflect the full array of comments. 

This article was originally published in Food Processing.

Sarah Levy, MPH, RD, is a vice president at FoodMinds, and leads FoodMinds’ Food and Nutrition Affairs team, which specializes in navigating the food and nutrition policy space. For more information about the analysis, contact us at [email protected].


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