Some Food Packaging May Soon Contain a Standardized “Healthy” Logo. Why, and What Is “Healthy?”

 For years, the Food and Drug Administration (FDA) has considered revising how it defines the term “healthy.” This April, the FDA is due to publish its updated definition of the term, which would change which foods manufacturers could legally claim are healthy. The definition has not been updated since 1994. That said, what makes this change particularly relevant for manufacturers and consumers is not the change in definition, which is “unlikely to significantly change which foods would be eligible [under] the new [definition].” Rather, it is that FDA is also due to release a new logo that manufacturers could put on food to denote that their product is healthy – basically a healthy stamp, similar to the USDA Organic insignia. (Draft versions of FDA’s “Healthy” symbol can be seen here.).

The FDA has the authority under the Food, Drug and Cosmetic Act (FD&C Act) to promulgate regulations over the types of claims that can be made on food packaging. This includes the power to define terms, such as “healthy.” Several alternatives exist for food manufacturers who cannot meet FDA’s definition of “healthy”, however. FDA very loosely regulates several terms which manufacturers use to convey a sense of health to consumers, such as “natural”. No such logos exist for those terms, though, potentially incentivizing food manufacturers whose products are on the fringe of FDA-defined healthiness to adjust their products’ ingredients.

That said, why put resources into developing an official “healthy” logo? Although it may not be likely to change what every shopper puts in their cart, the initiative is motivated by research suggesting that front-of-pack (FOP) labels, particularly those with an endorsement from some institutional authority (like FDA or USDA), make it easier for consumers to evaluate what they are purchasing. Obviously, part of the reason for this is the time crunch – it is easier to recognize a logo than it is to search the packaging or research a product. However, the location of information on packaging is important as well, as the FDA is also considering FOP nutrition facts, since some consumers are unlikely to look at the back of food packaging. These mini-labels would highlight added sugars, saturated fat and sodium – things consumers might want to see.

What does it mean for a food to be “healthy,” though? When FDA was taking comments over their new proposed rules, many comments philosophically questioned how FDA planned to draw a single line between healthy and unhealthy nutritional contents. While the proposed update to the definition bases itself on the Dietary Guidelines for Americans, 2020-2025 and mainly creates limits based on the percentage of Daily Value for added sugars, saturated fat and sodium, there are reasonable objections to the existence of the definition. If some food product manufacturers are going to be winners under the new “healthy” logo scheme, then other manufacturers that sell food products that could reasonably be a part of a healthy diet may unfairly take a hit. At the same time, a more detailed system of labeling, such as a health rating system or logos identifying specific nutrients, would potentially undermine the simplicity of FOP logos.

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