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Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices (2012)

Chapter:7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients

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Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
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7

A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients

INTRODUCTION

This chapter describes the characteristics of a model front-of-package (FOP) symbol system and presents an approach for evaluating food and beverage products for the amount of saturated and trans fats, sodium, and added sugars. This chapter also presents evaluation criteria for products using the term “points” to indicate that a critical component nutrient met its defined criteria, discusses how nutritional criteria might be based on current Food and Drug Administration (FDA) regulations for labeling nutrient content and health claims, and highlights the strengths, limitations, and regulatory issues pertaining to such a system. The assessment is based on a convenience sample of food and beverage products whose relevant nutrition information is provided in Appendix E.

The Phase I committee concluded that added sugars should not be a component of an FOP nutrition rating system because of insufficient evidence about the contribution of added sugars beyond calories to the most pressing diet-related health concerns among Americans; the inability to distinguish analytically between added and naturally occurring sugars in foods without obtaining proprietary product information and including that information on the Nutrition Facts panel (NFP); and the relatively small number of food categories with high amounts of added sugars. This committee reconsidered this Phase I conclusion in light of events occurring after the release of the Phase I report, specifically the release of the 2010 Dietary Guidelines for Americans and the development of an approach to evaluating added sugars content. The 2010 Dietary Guidelines for Americans, which is the federal government’s nutrition policy document, strongly recommends reducing intakes of calories from added sugars and consumption of foods containing added sugars. These products contribute to energy intake; generally contain no or low amounts of saturated and trans fats and sodium; and provide little or no essential nutrients unless fortified, which is not consistent with FDA fortification policy.1 A relatively small number of food and beverage categories contribute more than half the added sugars in the American diet.

The development of criteria, discussed in this chapter, to evaluate foods with added sugars makes it possible to give no FOP points to such foods while allowing some foods that contain small amounts of added sugars to earn FOP points. The committee’s approach addressed previous logistical issues around determining added sugars content that would allow some foods that are major contributors of added sugars to the diet, i.e., beverages and sweets, to erroneously appear to be healthy because they are low in saturated and trans fats and sodium.

The strong recommendation from the 2010 Dietary Guidelines for Americans, along with the development of

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1 21 CFR 104.20.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

this approach to evaluating added sugars, led the committee to conclude that added sugars are an important component that should be included in an FOP nutrition rating system. This conclusion is consistent with the principle that an FOP symbol system should not inadvertently promote products that are inconsistent with current federal dietary guidance.

FRONT-OF-PACKAGE MODEL SYSTEM

The committee reviewed published evidence and data submitted by stakeholders and consultants and developed conclusions about FOP systems that will be effective in attracting consumer attention and encouraging them to make healthier food choices. Specifically, the committee’s examination of the totality of the available evidence led to the following conclusions:

•   To be effective, FOP nutrition labels must compete in a very busy and ever-changing package environment that includes an array of messages designed to capture consumer attention and promote products.

•   Nutrition information provided in an FOP symbol system should be based on the most recent Dietary Guidelines for Americans and current consensus reports.

•   There is a need for a standardized FOP nutrition rating system that moves beyond providing information to one that encourages product comparison and healthier food choices by consumers at the point of purchase.

•   FOP systems that are simple and easy to understand more effectively encourage consumers to choose healthier products.

•   Consumers are making point-of-purchase decisions about food products in very little time and in the face of a diverse and growing number of stimuli on food packages.

•   Campaigns that guide consumers to look in a specific location for the specific symbol would maximize the use and benefit of an FOP system.

Furthermore, the committee identified three outcomes that an FOP system should produce in order to be successful among a broad range of consumers. The system must:

•   encourage consumers to make healthier choices at the point of purchase,

•   encourage food and beverage companies to provide healthier offerings by reformulating products or developing new ones, and promoting those healthier offerings, and

•   encourage retailers to highlight those healthier offerings.

POTENTIAL FOR SUCCESS

Given the goal of increasing healthier choices, the committee looked closely at a number of FOP and shelf tag systems that have demonstrated some success in the marketplace. The committee focused less on what consumers said and more on what they did, as measured by in-market retail sales. The committee also focused on consumers’ processing and use of nutrition rating symbols in a cluttered on-package environment. Based on the evidence reviewed in the preceding chapters, the committee determined that the type of nutrition rating symbol system most likely to be successful in enabling healthier food choice and purchase decisions will be:

•   simple, understanding does not require specific or sophisticated nutritional knowledge;

•   interpretive, nutrition information is provided as guidance rather than as specific facts;

•   ordinal, nutritional guidance is offered through a scaled or ranked approach; and

•   supported by communication with readily remembered names or identifiable symbols.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

CHARACTERISTICS OF A MODEL FOP SYMBOL SYSTEM

In addition to the three outcomes of an effective FOP system, the committee identified eight characteristics that are essential to the success of an FOP system. These characteristics are:

1.  One simple, standard symbol translating information from the NFP on each product into a quickly and easily grasped health meaning, making healthier options unmistakable. “Health meaning” refers to the extent to which a product contains reasonable amounts of three nutrient components (saturated and trans fats, sodium, and added sugars) considered harmful to health when consumed in excess or above a certain threshold. All information currently on the NFP would remain on the NFP. The committee suggested adding, on the FOP, a simple summary symbol offering nutritional guidance on that information.

2.  Displaying:

  a. Calories in common household measure serving sizes, and

  b. Zero to three nutritional “points.” The more points, the more the food or beverage helps consumers avoid less healthy levels of nutrients identified as being associated with diet-related health risks. Specifically, a food or beverage product could earn one point for an acceptable level of sodium, one for an acceptable level of saturated and trans fats, and/or one point for an acceptable level of added sugars. Saturated and trans fats are considered together to facilitate communication about limiting consumption of foods containing solid fats (USDA, 2010). If a food or beverage product contains any one of the nutrient components of concern in amounts exceeding specified criteria limits, then the product would not be eligible for points (see examples and discussion of points below). A similar system could be developed for shelf tags for unpackaged or bulk items such as fruits and vegetables as well as packaged goods.

3.  Appearing on all grocery products allowing consumers to compare food choices across and within categories. If all products displayed the FOP symbol system, then it would be easier for consumers to make healthier food choices both within and across food categories. If, however, consumers come to perceive products not displaying the FOP symbol system as less healthy alternatives, then they would in essence “use” the system even if it did not appear on all products;

4.  Appearing in a consistent location across products. Chapter 4 discusses the benefits of minimizing processing time. Chapter 6 discusses the benefits of characteristics that capture consumer attention, including color and contrast. If symbols are placed on a consistent, as opposed to unpredictable, FOP location, then it will take less time for consumers to process the information;

5.  Practical to implement because the FOP symbol system is consistent with nutrition labeling regulations. FDA and the U.S. Department of Agriculture’s (USDA’s) Food Safety and Inspection Service have developed extensive regulations for nutrition labeling, determining labeled serving sizes and explicit and implied nutrient content claims, and declaring ingredient content. These regulations were developed based on science and with public input from an array of interested parties through a formal rulemaking process and are publicly available;

6.  Integrated with the NFP so that the FOP symbol system and the NFP are mutually reinforcing. A FOP symbol system and the NFP can be integrated by placing a check, star, or other indicator inside or next to the NFP adjacent to the nutrition component earning the point. In this way, those who are interested can easily see what component(s) earned a point. When the NFP is displayed in the basic vertical format,3 or linear format4 it is not possible to place the check or other indicator just outside the box and adjacent to the name of the nutrient earning the point. Accordingly, it would be preferable to consistently have the check or other indicator inside the box for all NFP formats. The committee recognizes that current regulations would need to be modified to allow a

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2 21 CFR 101.9(d)(12).

3 21 CFR 101.9(j)(13)(iii) or 101.9(j)(13)(ii)(A)(1).

4 21 CFR 101.9(j)(13)(ii)(A)(2).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
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   check or other indicator within the NFP. Rulemaking to provide for such a modification could accompany rulemaking to establish an FOP system;

7.  Providing a nonproprietary, transparent translation of nutrition information into health meaning. Ease of compliance and enforcement requires publicly available and standardized nutrition criteria. An FOP nutrition rating symbol system that displays earned nutrient points based on criteria consistent with labeling regulations is nonproprietary, transparent, and can easily be monitored for compliance; and

8.  Made prominent and useful to consumers through an ongoing and a frequently refreshed program of promotion integrating the efforts of all concerned parties.

Brands invest in frequent consumer communications that maintain the power and salience of their brand symbols. Without that continual, frequent communication, any symbol can fade from interest and exert less and less influence on choice (Hasher and Zacks, 1984; Romaniuk and Sharp, 2004; Wixted, 2004). Similarly, without frequent communication from the brand to the consumer, any FOP symbol system will fade from interest and become less and less useful in helping consumers make healthier choices. A readily remembered name or “brand” for the FOP symbol would facilitate communication to consumers by increasing its salience and encouraging its use. This need for the FOP system dovetails with the objectives of many governmental and nongovernmental organizations and food manufacturers that are interested in helping consumers make healthier choices and reduce diet-related chronic disease risk—USDA, FDA, the Centers for Disease Control and Prevention (CDC), the American Heart Association, the American Diabetes Association, the American Dietetic Association, and the Grocery Manufacturer’s Association, among others. Integrating the efforts of these concerned parties behind the FOP system can contribute dramatically to its ability to increase healthier food choices by consumers.

In addition, a well-designed FOP symbol system would also stimulate competition among food and beverage companies to provide the consumer with the most desirable options that do not lead to or contribute to diet-related chronic disease. A well-designed FOP symbol system should be a competitive opportunity.

Examples of FOP Symbols

The committee commissioned two graphic designers to produce examples of FOP symbols that incorporate to varying degrees the communication and design concepts discussed above. The examples in Figures 7-1 through 7-3 illustrate different visual interpretations of FOP symbol systems for food product packages. Each figure displays a series of four hypothetical food product packages showing the two-component symbol system of calories per serving (expressed in household measures) and a nutrient component rating symbol. Each system is also displayed in three “usage” samples: the FOP symbol, a shelf tag, and the NFP with a tie-in to the FOP symbol. It is important to note that the committee does not endorse any particular design or product; these examples are presented for illustrative purposes only. The committee encourages regulators and industry stakeholders to engage in a process of selecting and designing an effective FOP symbol system based on the committee’s recommendations, and incorporating effective design elements such as color and contrast (see Chapters 6 and 9 for additional information).

APPROACH TO EVALUATING PRODUCTS FOR FOP POINTS

When developing the approach to evaluating food products the committee considered the eight characteristics described in the previous section for a model FOP system as well as factors that would influence its assessment of food products. This section describes the approach and discusses the overall strengths and limitations of potential nutritional criteria as well as of each nutrient category.

A model FOP symbol system displays calories and serving size information, as described by characteristic 2a, and indicates acceptable levels of saturated and trans fats, sodium, and added sugars in food and beverage products. It also excludes products from earning points for acceptable amounts of these nutrient components if any one component exceeds a specified limit (described by characteristic 2b). Products are ineligible for FOP points if one (or more) of the nutrient components is present in an amount that exceeds a specified limit. Additionally, a model FOP symbol system must be consistent with nutrition labeling regulations as described by characteristics

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×
Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×
Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×
Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

BOX 7-1
Definition of Terms Used in Setting Nutritional Criteria

Front-of-Package (FOP) point: A point that indicates that a critical nutrient component met its defined eligibility and qualifying criteria for inclusion in the FOP symbol system.

Nutrient content claims: Claims on food package labels that characterize and describe the level of a nutrient or dietary substance in the product.

Disclosure level: The threshold amount at which certain nutrients, including saturated fat and sodium, in products must be disclosed when making nutrient content claims.

Disqualifying level: The threshold amount at which certain nutrients, including saturated fat and sodium, in products disqualify a product from making health claims.

Daily Value (DV): Reference values established by the Food and Drug Administration (FDA) and used in nutrition labeling. DV are based on recommended daily intake levels of nutrients needed for health.

Percent DV: Percentages found on the Nutrition Facts panel on food labels that put the amount of nutrients in the product in the context of a total diet.

Reference Amounts Customarily Consumed (RACC): The amount of a food customarily consumed per eating occasion by persons in a population group as determined by FDA. RACC is used as the regulatory basis for determining labeled serving sizes on the Nutrition Facts panel.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

5 and 7. A model FOP system requires a clear, systematic procedure for determining whether a given product earns zero, one, two, or three points, and the criteria used to assess products for points should balance restrictiveness with practicability. An FOP system will function among a variety of constraints and resources, which offer both guidance and complexity. Box 7-1 describes and defines the terms used in setting nutritional criteria. When developing the approach to evaluating food products the committee considered the following factors:

•   Evaluation of a convenience sample of food and beverage products against relevant criteria for nutrition labeling, nutrient content and health claims, and ingredient labeling related to saturated fat, trans fat, sodium, and added sugars;

•   Consideration of recommendations in the Dietary Guidelines for Americans (USDA, 2010) and products that have been determined based on their nutritional value to be eligible for use in federal food programs such as the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC);5 and

•   Identification of potential options for addressing discrepancies between product ratings based on current regulations and dietary recommendations and WIC eligibility.

6 and their relevant nutrition information that were evaluated by the committee. Nutrition and ingredient information was obtained from the NFP on product labels, manufacturers’ websites, an online database of NFPs and ingredient statements,7 and the USDA Food and Nutrient Database for Dietary Studies, 3.0 (ARS, 2008). Each is only one of many examples of products within a product category and may not be representative of all products in its category. Each product is considered an individual food under FDA regulations, as compared to main dishes and meal products. Current regulations for nutrient content claims are consistent across all product categories of individual foods and differ from regulations for main dishes and meal products to

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5 Available online: http://www.fns.usda.gov/wic/benefitsandservices/foodpkgregs.htm (accessed March 15, 2011).

6 It is Institute of Medicine (IOM) policy to not use brand names of products.

7 Available online: http://www.peapod.com/ accessed on various dates throughout 2010 and 2011).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

recognize that each type of product makes a different relative contribution to the total diet. The committee did not evaluate mixed dishes (a category of individual foods), main dishes, and meal products because of the complexity of the task and resource constraints.

Approach to Evaluating Nutrients to Limit in an FOP Symbol System

The committee notes that no one FOP symbol system, including its underlying nutrition criteria, is flawless. The proposed approach for evaluating nutrients to limit in an FOP symbol system addresses the purposes and has the strengths and limitations listed in Box 7-2 and discussed in the evaluation of nutritional criteria. A much more extensive evaluation of foods and beverages against potential criteria is needed to fully identify the strengths and limitations of the proposed approach and current regulations.

The committee considered the diversity of the food supply as well as the nutrient content of individual foods. Because of this diversity there will always be particular foods or food categories that do not appear to appropriately qualify, or not qualify, for earned “points.” Although criteria based on existing labeling regulations are transparent and nonproprietary, the described approach would require modifications or exemptions to existing regulations and the development of new regulations to implement the model FOP symbol system.

NUTRITIONAL CRITERIA

The committee determined that an FOP symbol system should not inadvertently promote products that contain amounts of saturated and trans fat, sodium, or added sugars that are inconsistent with Dietary Guidelines recommendations. Therefore, the committee developed a two-step process for evaluating products that, first, assesses products for eligibility for FOP points (see Figure 7-4), and, second, evaluates products for points.

Step 1: Eligible or not? Eligibility criteria determine whether a product may earn FOP points for saturated and trans fats, sodium, or added sugars. If the product contains an amount of one or more of the stated nutrient components that is not consistent with Dietary Guidelines recommendations, then it is ineligible for FOP points.

Step 2: If eligible, for how many points? If a product is eligible for FOP points, then qualifying criteria determine whether the product earns zero, one, two, or three FOP points. The qualifying criteria in general are more restrictive than the eligibility criteria.

In Step 1, a food or beverage can be excluded from earning FOP points for saturated and trans fats, sodium, and added sugars because the amount of any one of those components is considered “too high,” that is, it contains an amount of saturated fat, trans fat, sodium, and/or added sugars and that is inconsistent with Dietary Guidelines recommendations. For example, a product “high” in sodium but containing no or low levels of saturated and trans fat and added sugars would not be eligible for FOP points. Such a product should be excluded from earning FOP points for saturated and trans fats and added sugars even if the amounts of these nutrient components otherwise meet qualifying criteria. In the second step, a food or beverage that meets the eligibility criteria can then be evaluated for FOP points for saturated and trans fats, sodium, and added sugars. These steps are illustrated in Figure 7-4.

Eligibility Criteria

The committee outlined a potential approach to setting eligibility criteria that would use nutrient levels set by FDA that define the point at which a food product can make a health claim or nutrient content claim. FDA defines these “disclosure/disqualifying” criteria as no more than 20 percent of the Daily Value (DV) for certain nutrients (see Glossary for definition) whose consumption in excess “can lead to a diet inconsistent with dietary guidance for maintaining good health.”8 Accordingly, FDA has set >20 percent DV as the threshold amount at which certain

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8 58 FR 2478 at 2494; January 6, 1993.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

BOX 7-2
Purposes, Strengths, and Limitations of the Described Approach for Evaluating
Nutrients to Limit in the Model Front-of-Package (FOP) Symbol System

Purposes

The model FOP symbol system:

•   Provides consumers with prominent calorie content information

•   Provides prominent serving size information

•   Provides targeted information related to saturated and trans fats, sodium, and added sugars

•   Facilitates consumers’ comparisons of nutritional value within food categories

•   Facilitates consumers’ comparisons of nutritional value across most food categories

Encourages manufacturers to reformulate products

Strengths

The model FOP symbol system:

•   Targets nutrients of public health concern

•   Provides a measure of the relative amount of saturated and trans fats, sodium, and added sugars by assigning points when a product contains qualifying amounts of these nutrients

•   Evaluates nutrient amounts consistent with science-based regulations

•   Applies one set of nutritional criteria across all or most product categories similar to current regulations, with certain exceptions where technically needed

•   Facilitates compliance with recommendations from the Dietary Guidelines for Americans

•   Allows compliance to be monitored, either by chemical analysis of nutrient levels or by review of the ingredient list

Limitations

In the approach to evaluating products:

•   Many foods that are consistent with the recommendations of the Dietary Guidelines for Americans or that are eligible for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) exceed the disclosure level for saturated fat.

•   Most foods, including those that are consistent with the recommendations of the Dietary Guidelines for Americans or that are WIC-eligible, do not meet criteria for “low saturated fat.”

•   No disclosure level or regulatory criteria defines “low” for trans fat.

•   Most foods, including those that are consistent with the recommendations of the Dietary Guidelines for Americans or that are WIC-eligible, do not meet criteria for “low sodium.”

•   No disclosure level or regulatory criteria exists for “low” added sugars.

Many of these attributes were among those identified and used by the Phase I committee to evaluate existing types of FOP symbol systems (IOM, 2010a).

nutrients, including saturated fat and sodium, in individual foods must be disclosed when making nutrient content claims (disclosure levels)9 or which disqualify a product from making health claims (disqualifying levels).10 The committee believes that >20 percent DV is an appropriate eligibility criterion for saturated fat and sodium for an

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9 21 CFR 101.13(h).

10 21 CFR 101.14(a)(4).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

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FIGURE 7-4 Evaluation criteria for a front-of-package symbol system.

FOP system. Disclosure/disqualifying levels for main dishes (>30 percent DV) and meal products (>40 percent DV) could also be used as eligibility criteria for these types of products.

FDA has not defined disclosure/disqualifying levels for trans fat and added sugars in part because of the absence of the type of quantitative information from authoritative scientific groups on which the agency could support the establishment of a Daily Reference Value.11 However, in accordance with dietary guidance that recommends that trans fat intake be kept as low as possible, especially by limiting foods that contain synthetic sources of trans fat (IOM, 2005; USDA, 2010, p. 21), a product’s trans fat content can be evaluated when determining whether it qualifies for an FOP point for saturated and trans fats (see Qualifying Criteria for FOP Points). A product’s added sugars content can be evaluated for eligibility based on the approach described below.

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11 68 FR 41434; July 11, 2003.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-1 Saturated Fat Content of Example Foods That Exceed the Food and Drug Administration (FDA) Disclosure/Disqualifying Level for Saturated Fata

Saturated Fat Content Percent of
Productb Labeled Serving g/LS g/50 g Calories
Parmesan cheese 2 tsp (5 g) 1 10 45
Mozzarella cheese, part skim 1 oz (28 g) 3 5.1 36
Cheddar cheese, reduced fat 1 oz (28 g) 3.5 5.8 37
Cheddar cheese, 2% fat milk 1 oz (30 g) 4 6.7 40
Cheddar cheese, regular 1 oz (28 g) 5 8.9 41
Vanilla ice cream, regular fat 0.5 cup (66 g) 4.5 NA 29
Olive oil 1 tbsp (15 mL) 2 6.7 15
Peanut oil 1 tbsp (14 g) 2.5 8.9 19
Soybean oil 1 tbsp (14 g) 2 7.1 15
Mayonnaise 1 tbsp (13 g) 1.5 5.8 15
Salad dressing, regular 1 2 tbsp (30 g) 2.5 4.2 16
Margarine, soft 1 1 tbsp (14 g) 2 7.1 26
Margarine, soft 2 1 tbsp (14 g) 2.5 8.9 28
Margarine, soft 3 1 tbsp (14 g) 1.5 5.4 17
Margarine, stick 1 tbsp (14 g) 2.5 8.9 22
Butter, unsalted 1 tbsp (14 g) 7 25 63
Peanut butter 2 tbsp (32 g) 3 4.7 14
Potato chips 16 pieces (30 g) 2.5 4.2 15
Chicken thighs, raw boneless skinlessc 4 oz (114 g) 5 NA 19

NOTES: LS = labeled serving, NA = the small RACC rule does not apply, RACC = reference amounts customarily consumed.

a Contains >4 g per RACC and LS, or per 50 g if RACC is small. 21 CFR 101.13(h)(1).

b Products followed by numbers represent different brands.

c Poultry is regulated by the U.S. Department of Agriculture (USDA) and not subject to FDA disclosure regulations. Chicken thighs were included for illustrative purposes only.

Eligibility Criteria for Saturated Fat Table 7-1 lists the saturated fat content of example products evaluated by the committee that exceed FDA disclosure/disqualifying level. These example products would not be eligible to earn FOP points, even if the levels of other nutrients met the FOP qualifying criteria.

One limitation of using >20 percent DV for setting eligibility criteria is that some products that are consistent with Dietary Guidelines recommendations would be excluded, such as olive, peanut, and soybean oils; mayonnaise and some regular salad dressings; and soft margarines with liquid vegetable oil as the first ingredient (USDA, 2010, p. 40). Other products that would be excluded are WIC-eligible products,Table 7-1 are not eligible based on the small Reference Amounts Customarily Consumed (RACC) rule, i.e., their RACC is 30 g or less or 2 tablespoons or less, and they contain more than 4 g of saturated fat per 50 g. Three potential solutions are suggested.

First, FDA could develop exemptions to avoid excluding oils, nuts, and foods containing oils and nuts recommended in the Dietary Guidelines, perhaps based on a product’s saturated fat content being no more than 15 percent of total calories, a criterion used in the FDA regulation for “low saturated fat.” However, even with such an exemption, peanut oil, some salad dressings, and soft margarines would still be ineligible, which suggests a need for some other basis for exempting fats and oils encouraged by the Dietary Guidelines.

Second, when reduced-fat versions of cheese that are WIC-eligible are evaluated against the disclosure/disqualifying level for saturated fat, FOP points also would not be allowed13 even though suggested as alternatives to full fat cheeses in the 2010 Dietary Guidelines for Americans (p. 65). However, this may be appropriate inasmuch

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12 Available online: http://www.fns.usda.gov/wic/benefitsandservices/foodpkgregs.htm (accessed March 15, 2011).

13 See footnote 1.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-2 Sodium Content of Example Products That Exceed the Food and Drug Administration (FDA) Disclosure/Disqualifying Level for Sodiuma

Sodium
Productb Labeled Serving mg/LS mg/50 g
Parmesan cheese 2 tsp (5 g) 85 850
Salad dressing, regular 2 2 tbsp (30 g) 370 617
Mustard 1 tsp (5 g) 120 1200
Pretzels 9 pieces (28 g) 560 1000
Soup crackers 35 pieces (15 g) 170 567
Soups, regular varieties 0.5 cup (120 mL) 650+ NA
Tomato juice 0.5 cup (120 mL) 680 NA

NOTES: LS = labeled serving, NA = the small RACC rule does not apply, RACC = reference amounts customarily consumed.

a Contains >480 mg per RACC and LS, or per 50 g if RACC is small. 21 CFR 101.13(h)(1).

b Products followed by numbers represent different brands.

as the Dietary Guidelines recommends an increase in the intake of fat-free or low-fat milk and milk products rather than cheese in order to decrease not only saturated fat but also sodium intake (USDA, 2010, p. 38).

Third, poultry products are subject to USDA regulations (see Chapter 3), which do not include disclosure or disqualifying levels. However, chicken thighs were evaluated in order to assess the impact of applying FDA’s disclosure/disqualifying level to such a product.

Eligibility Criteria for Sodium Several example products exceeded the FDA disclosure/disqualifying level for sodium (14 mustard, pretzels, one of four salad dressings, soup crackers, three of four regular canned soups, and a tomato juice. These example products would not be eligible to earn FOP points, even if the levels of the other nutrients met the FOP qualifying criteria. For saturated and trans fats and added sugars, however, similar products formulated to contain sodium that do not exceed the disclosure level, e.g., a low-sodium tomato juice, would be eligible.

Eligibility Criteria for Added Sugars A relatively small number of food and beverage categories contribute more than half the added sugars in the American diet: regular soda, energy drinks, and sports drinks (35.7 percent), fruit drinks (10.5 percent), candy (6.1 percent), and sugars and honey (3.5 percent) (USDA, 2010, p. 29). Collectively categorized as Sugars, Sweets, and Beverages in the USDA Food and Nutrient Database for Dietary Studies (USDA, 2008, pp. 93-100), these products contribute to energy intake; generally contain no or low amounts of saturated fat, trans fat, and sodium; and provide little or no essential nutrients unless fortified, which would be inconsistent with FDA fortification policy.15 The 2010 Dietary Guidelines for Americans 2010 recommends limiting their consumption (p. 67). Accordingly, any product that is categorized as Sugars, Sweets, and Beverages and contains added sugars would not earn FOP points for saturated and trans fats and sodium even though the levels of those nutrients met the FOP qualifying criteria.

Other major contributors to added sugars intake include grain-based desserts (12.9 percent), dairy-based desserts (6.5 percent), and ready-to-eat cereals (3.8 percent) (USDA, 2010, p. 29). Some products in these categories can make meaningful contributions to dietary fiber and/or essential nutrient intakes and therefore should be evaluated for potentially earning FOP points. Some grain-based and dairy-based desserts may be excluded because they exceed eligibility criteria for saturated fat and/or sodium content. Eligible grain-based and dairy-based desserts and ready-to-eat cereals can be evaluated against the qualifying criteria for FOP points for saturated and trans fats, sodium, and added sugars.

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14 Parmesan cheese also would not be eligible based on saturated fat content. See Table 7-1.

15 21 CFR 104.20.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-3 Examples of Products Categorized as Sugars, Sweets, or Beveragesa

Product Reason
Cola soft drink Sweetened beverage
Lemon-lime soft drink Sweetened beverage
Sweetened tea Sweetened beverage
Lemon-lime sport drink Sweetened beverage
Chocolate-peanut candy Sweets
Apricot preserves Sweets

a USDA Food and Nutrient Database for Dietary Studies (USDA, 2008, pp. 93-100).


Table 7-3 lists example products that would not be eligible for earning points for saturated and trans fats and sodium because of added sugars content.

Qualifying Criteria for Nutrient Component FOP Points

If a food or beverage product meets the more general criteria for eligibility for FOP points, then it can be evaluated according to qualifying criteria to determine whether it qualifies for one or more FOP points for saturated and trans fats, sodium, or added sugars.

Qualifying Criteria for Saturated and Trans Fat FOP Point

A practical approach for an FOP symbol system would be to evaluate the amount of saturated fat and trans fat separately. The NFP provides information on the content of both components, which together are referred to as “solid fats” in the Dietary Guidelines (USDA, 2010, p. 27). If the qualifying criteria for both saturated fat and trans fat are met, then a product would earn at least one FOP point.

Regarding saturated fat, FDA has defined criteria for several claims that characterize the amount of saturated fat in products, which could be used to qualify products for one FOP saturated fat point (Table 7-4). The saturated

TABLE 7-4 Criteria for Nutrient Content Claims That Characterize the Amount of Saturated Fat a

Product Type Low Healthy Extra Lean Lean
Individual foods =1 g per RACC and =1 g per RACC and NA NA
=15% of calories =15% of calories
Seafood and game meat =1 g per RACC and <2 g per RACC and <2 g per RACC and =4.5 g per RACC and
=15% of calories 100 g 100 g 100 g
Main dishesb and meal =1 g per 100 g and =1 g per 100 g and <2 g per 100 g =4.5 g per 100 g and LS
productsc =10% of calories =10% of calories and LS
Mixed dishes not NA NA NA =3.5 g per RACC
measurable with a cupd

NOTES: LS = labeled serving size, NA = these claims do not apply to the identified product type RACC (reference amounts customarily con­sumed).

a SOURCE: 21 CFR 101. Food labeling Guide: Guidance for Industry. September 1994; revised April 2008. Food and Drug Administra­tion. See Appendices A and B. Available online: http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/FoodLabelingNutrition/FoodLabelingGuide/default.htm (accessed May 18, 2011).

b Defined in 21 CFR 101.13(m).

c Defined in 21 CFR 101.13(l).

d Defined in 21 CFR 101.12(b) in Table 7-2.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

fat criteria for “healthy”16 individual foods and main dishes and meal products are the same as for “low” saturated fat.17 Similarly the criteria for “healthy”18 saturated fat in seafood and game meat are the same as for “extra lean.”19 Claims for “healthy,” “lean,” and “extra lean” include criteria for other nutrients, such as total fat and cholesterol; these additional criteria need not apply if the saturated fat criteria were used for qualifying a product for an FOP saturated fat point.

Regarding trans fat, FDA has not defined criteria for “low” levels because of the lack of a basis for determining a DV. Given the absence of defined criteria for characterizing the amount of trans fat in foods and beverages, an approach for qualifying a product for an FOP saturated and trans fat point is to use FDA regulations for declaring the amount of trans fat in the NFP. For example, a product could qualify if its NFP declares 0 g trans fat per serving (i.e., less than 0.5 g per labeled serving).20 A product could also qualify if the NFP declares 0.5 g or more trans fat per serving and the ingredients statement does not list a partially hydrogenated vegetable oil. Any trans fat in such products would be from naturally occurring sources. Limits on the qualifying amount of saturated fat would limit the amount of naturally occurring trans fat (USDA, 2010, p. 26).

To assess this approach, the committee evaluated several example foods, including poultry products, against criteria for “low saturated fat” and for labeled trans fat content. Table 7-5 lists example products that were not “low” in saturated fat and/or that declared 0.5 g or more trans fat in the NFP and a partially hydrogenated vegetable oil in the ingredients statement—products that would not, under this system, receive an FOP point for saturated and trans fats. This analysis included olive, peanut, and soybean oils; all three examples of soft margarines with liquid vegetable oil as their first ingredient; a mayonnaise; one of two examples of regular salad dressings; and peanut butter even though they exceeded the disclosure/disqualifying level for saturated fat and would not be eligible for FOP points unless exempted by FDA. As mentioned above, chicken thighs (regulated by USDA) would not be eligible if evaluated against FDA’s disclosure/disqualifying level, but were included for illustrative purposes.

The sugar cookie example illustrates a case in which a product can be low in saturated fat, but not qualify because it contains 1.5 g trans fat per labeled serving and lists a partially hydrogenated oil in the ingredients statement. In contrast, the chocolate chip cookie and snack cracker examples would not qualify because of both saturated fat and trans fat content. And, the breakfast bar and toaster pastry examples would not qualify because of saturated fat content even though they contained no trans fat.

However, qualifying a product for an FOP saturated fat point based on criteria for “low saturated fat” may be too restrictive. Several of the example products are consistent with Dietary Guidelines recommendations or are WIC-eligible but would not qualify for a point if evaluated against “low saturated fat” criteria. The 1 percent fat milk, olive and soybean oils, mayonnaise, a salad dressing, the four salmon examples, and walnuts contain .15 percent of total calories from saturated fat but 1.1 to 2.6 g per RACC (ranging from 5.5 to 13 percent DV). The peanut oil, three soft margarines, chicken thighs, and WIC-eligible eggs and peanut butters also would not qualify.

As a means of expanding the range of products that qualify for a saturated fat point, FDA should evaluate the appropriateness of a qualifying saturated fat criterion based on no more than 10 percent DV per RACC (i.e., no more than 2 g per RACC), an amount that may be viewed as “moderate,” without a percentage of calories criterion. Such a criterion would qualify the breakfast bar, toaster pastry, 1 percent fat milk, egg, olive and soybean oils, soft margarines 1 and 3, mayonnaise, two of three salmon products, and walnuts. To be consistent with WIC, the qualifying criteria for eligible peanut butter could be increased to 3 g per RACC.Table E-2). The criteria for “low saturated fat” and “extra lean” are also likely to be too restrictive for qualifying main dishes and meal products, although this was not evaluated by the committee.

image

16 21 CFR 101.65(d)(2).

17 21 CFR 101.62(c).

18 21 CFR 101.65(d)(2).

19 21 CFR 101.62(e)(4).

20 21 CFR 101.9(c)(2)(ii).

21 This presumes peanut butters are exempted from the eligibility criteria.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-5 Saturated Fat Content of Selected Example Products Compared to Criteria for “Low in Saturated Fat” and Content of Trans Fat and Partially Hydrogenated Vegetable Oil

    Saturated Fat      
          Not Contains
  Labeled     Percent of Low TFA and
Producta Serving g/LS g/RACC calories SFAb PHVOc
Sugar cookies 4 (40 g) 1 <1 7   x
Chocolate chip cookies 1 pkg (42 g) 3 2.1 13 x x
Snack crackers 9 (32 g) 2 1.9 12 x x
Breakfast bar 1 bar (40 g) 2 2 12 x  
Toaster pastry 1 pastry (52 g) 2 1.5 9 x  
Milk, 1% fat 1 cup (240 mL) 1.5 1.5 12 x  
Ricotta cheese, part skim 0.25 cup (62 g) 4 3.5 36 x  
Egg 1 large (50 g) 1.5 1.5 19 x  
Olive oil 1 tbsp (15 mL) 2 2 15 x  
Peanut oil 1 tbsp (14 g) 2.5 2.5 19 x  
Soybean oil 1 tbsp (14 g) 2 2 15 x  
Margarine, soft 1 1 tbsp (14 g) 2 2 26 x  
Margarine, soft 2 1 tbsp (14 g) 2.5 2.5 28 x  
Margarine, soft 3 1 tbsp (14 g) 1.5 1.5 17 x  
Mayonnaise 1 tbsp (13 g) 1.5 1.7 15 x  
Salad dressing, regular 1 2 tbsp (30 g) 2.5 2.5 16 x  
Salmon fillets, frozen raw 4 oz (114 g) 1.5 1.4 7 x  
Salmon fillets, raw 3 oz (85 g) 2.6 3.4 13 x  
Salmon steaks, raw 3.5 oz (99 g) 1 1.1 6 x  
Salmon, canned 0.25 cup (60 g) 1.5 1.4 12 x  
Chicken thighs, raw boneless skinlessd 4 oz (114 g) 5 5 19 x  
Walnuts, shelled 0.25 cup (30 g) 2 2 9 x  
Peanut butter 2 tbsp (32 g) 3 3 14 x  

NOTES: LS = labeled serving size, PHVO = partially hydrogenated vegetable oil, pkg = package, RACC = reference amounts customarily consumed, SFA = saturated fat, TFA = trans fat.

a Products followed by numbers represent different brands.

b Contains >1 g saturated fat per RACC and/or >15% of calories from saturated fat.

c Contains =0.5 g trans fat per LS and PHVO in ingredients statement.

d Poultry is regulated by the U.S. Department of Agriculture; chicken thighs were included for illustrative purposes only.

Extensive computer modeling is needed to compare the saturated fat content of a wide variety of products against various criteria to determine which approach results in products appropriately earning an FOP saturated fat point.

Qualifying Criteria for Sodium FOP Points

FDA has defined criteria for “low sodium” and “healthy” claims that characterize the amount of sodium in a product, which could potentially be used to qualify a product for an FOP sodium point (Table 7-6). Table 7-7 lists several example products that were evaluated against the sodium criteria for “low” claims (140 mg per RACC) and “healthy” claims (480 mg per RACC). Mayonnaise, a soft margarine, and peanut butter were included in this analysis even though they exceeded the disclosure/disqualifying level for saturated fat and therefore would not be eligible for evaluation for an FOP sodium point unless exempted by FDA.

Of the example products listed,22 only seven met the criteria for “low sodium” but all met the sodium criteria for “healthy.” Thus, qualifying criteria for an FOP sodium point based on the criteria for a “healthy” claim may be more realistic than one based on “low sodium.” Qualifying criteria based on “healthy” sodium would allow

image

22 The peanut butter example contains added salt and added sugars, but some peanut butters do not contain added salt and added sugars.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-6 Criteria for Nutrient Content Claims That Characterize the Amount of Sodium

 
Product Lowa Healthyb
 
Individual foodsc 140 mg per RACC (or per 50 g if RACC is small) =480 mg per RACC and LS (or per 50 g if RACC is small)
Main dishes and meal products 140 mg per 100 g 600 mg per LS
 

NOTES: LS = labeled serving size, RACC = reference amounts customarily consumed. A small RACC is 30 g or 2 tablespoons.

a 21 CFR 101.61(b)(4) and 101.61(b)(5).

b 21 CFR 101.65(d)(2)(ii).

c Includes seafood and game meat.

TABLE 7-7 Sodium Content of Selected Example Foods That Meet the Sodium Criteria for “Low” and/or “Healthy”

    Sodium mg per      
Producta Labeled Serving LS RACC 50 g Lowb Healthyc
100% whole wheat bread 1 slice (43 g) 170 198 NA no yes
Graham crackers 8 pieces (31 g) 180 174 290 no yes
Animal crackers 13 pieces (30 g) 75 75 125 yes yes
Breakfast bar 1 bar (40 g) 105 105 NA yes yes
Shredded wheat cereal 1 cup (49 g) 0 0 NA yes yes
Toasted oat cereal 1 cup (28 g) 160 NA 286 no yes
Crisped rice cereal 1.25 cup (33 g) 190 NA 288 no yes
Oatmeal, old-fashioned 0.5 cup (40 g) 0 0 NA yes yes
Oatmeal, instant plain 1 package (25 g) 75 120 NA yes yes
Oatmeal, instant with fruit and nuts 1 package (37 g) 190 282 NA no yes
Chocolate milk, 1% fat 1 cup (240 mL) 150 150 NA no yes
Yogurt, plain nonfat 1 cup (227 g) 190 188 NA no yes
Margarine, soft 1 1 tbsp (14 g) 100 100 357 no yes
Margarine, soft 2 1 tbsp (14 g) 90 90 321 no yes
Margarine, soft 3 1 tbsp (14 g) 85 85 304 no yes
Mayonnaise 1 tbsp (13 g) 70 81 269 no yes
Salad dressing, regular 1 2 tbsp (30 g) 260 260 433 no yes
Salad dressing, light 1 2 tbsp (31 g) 290 280 468 no yes
Salad dressing, light 2 2 tbsp (32 g) 290 272 453 no yes
Tuna fish, solid white in water ~0.25 cup (55 g) 190 190 NA no yes
Kidney beans, canned 0.5 cup (130 g) 360 360 NA no yes
Peanut butter 2 tbsp (32 g) 130 130 203 no yes
Soups, “healthy” 0.5 cup (120 mL) 410 410 NA no yes
Mixed vegetable juice, regular 1 can (5.5 oz) 330 480 NA no yes
Mixed vegetable juice, low sodium 1 can (5.5 oz) 80 116 NA yes yes
Tomato juice, low sodium 8 fl oz (240 mL) 140 140 NA yes yes
Tomatoes, canned 0.5 cup (121 g) 220 236 NA no yes

NOTES: LS = labeled serving size, NA = the small RACC rule does not apply, RACC = reference amounts customarily consumed.

a Products followed by numbers represent different brands.

b Contains ≤140 mg per RACC, or per 50 g if RACC is small. 21 CFR 101.16(b)(4).

c Contains ≤480 mg per RACC and LS, or per 50 g if RACC is small. 21 CFR 101.65(d)(2)(ii).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-8 Potential Qualifying Criteria for a Front-of-Package Added Sugars Point for Individual Foods

Total Sugars Content Condition and/or Rationale
0 g on NFP Meets criteria for “sugar free”a
0.5 g per RACC Products with no ingredient recognized as added sugars listed in the ingredients statementb
6 g per ounce Breakfast cereals that meet the WIC requirement for sugarsc
5 g per RACC Products with an ingredient recognized as added sugars except for canned products containing tomatoes and/or other vegetables and yogurt products and substitutesd
10 g per RACC Canned products with tomatoes and other vegetables that contain naturally occurring sugars as well as an ingredient recognized as added sugarse
20 g per RACC Yogurt products and substitutes that contain a low calorie sweetener and an ingredient recognized as added sugarsf

NOTES: LS = labeled serving size, NFP = Nutrition Facts panel, RACC = reference amounts customarily consumed, WIC = Special Supplemental Nutrition Program for Women, Infants and Children.

a Contains <0.5 g sugars per RACC and LS. 21 CFR 101.60(c)(1).

b Applies to products containing only naturally occurring sugars such as fruits, fruit juices, and milk.

c Contains no more than 21.2 g sucrose and other sugars per 100 g of dry cereal. Available online: http://www.fns.usda.gov/wic/benefitsandservices/foodpkgregs.htm (accessed March 15, 2011).

d This would qualify WIC-eligible peanut butters and canned mature legumes. The latter contains small amounts of added sugars to prevent stress resulting from the canning process; however, WIC does not specify what constitutes a small amount of sugar. The 5 g represents 20 calories or 1 percent of 2,000 calories. Available online: http://www.fns.usda.gov/wic/benefitsandservices/foodpkgregs.htm (accessed March 15, 2011).

e WIC requirements allow small amounts of sugars to be added to vegetables that are naturally sugar-containing during the canning process to prevent stress resulting in membrane rupture; however, WIC does not specify what constitutes a small amount of sugar. The 10 g represents 40 calories or 2 percent of 2,000 calories. Available online: http://www.fns.usda.gov/wic/benefitsandservices/foodpkgregs.htm (accessed March 15, 2011).

f Half the sugar should come from milk as estimated from the protein and lactose contents of plain yogurt and products expected to be covered by this criterion.

more foods that are consistent with the Dietary Guidelines recommendations and/or are WIC-eligible to earn an FOP sodium point, as well as foods that have been specially formulated to meet regulations for a “healthy” claim such as some soups and vegetable juices. The qualifying criteria also provide a more realistic target for product reformulation and new product development.

A limitation is that products that pass the eligibility criteria for sodium would automatically qualify for a sodium point based on “healthy,” because the cut-off for qualifying for an FOP sodium point based on “healthy” is the same as the cut-off for eligibility based on the disclosure amount. This limitation could be addressed by reducing the qualifying cut-off for sodium over time as part of an overall strategy to reduce sodium in the food supply.

Qualifying Criteria for Added Sugars

Although added sugars are not declared in the NFP, the committee identified an approach for determining whether a product qualifies for an FOP point for added sugars. The approach uses FDA’s claim criteria for “sugar free” and “no added sugars,” as well as the amount of total sugars declared on the NFP in conjunction with specific conditions. Potential criteria and associated rationale or conditions for individual foods are listed in Table 7-8. Criteria for meal products and main dishes could be developed and evaluated based on a similar approach.

FDA regulations provide for claims of “no added sugars” and “without added sugars” if no sugar or sugar-containing ingredient is added during processing. FDA defines “added sugars” as sugars or other ingredients added during processing or packaging that functionally substitute for sugars, such as fruit juice concentrates, jams, and jellies, and including ingredients that may functionally increase the sugars content of a food, such as enzymes.23

The Dietary Guidelines list the following as examples of added sugars: anhydrous dextrose, brown sugar, con-

image

23 21 CFR 101.60(c)(2).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-9 Sugars Content of Selected Example Foods That Do and Do Not Meet Potential Front-of-Package Criteria for Added Sugars

    Total Sugars Added Meets
Producta Labeled Serving g/LS g/RACC Sugars Criteriab
100% whole wheat bread 1 slice (43 g) 4 4.6 yes yes
Graham crackers 8 pieces (31 g) 8 7.7 yes no
Animal crackers 13 pieces (30 g) 8 8 yes no
Breakfast bar 1 bar (40 g) 9 9 yes no
Toasted oat cereal 1 cup (28 g) 1 1.1 yes yes
Sweetened toasted oat cereal 1 cup (28 g) 9 9.6 yes no
Oatmeal, instant plain 1 package (25 g) 0 0 yes yes
Oatmeal, instant with fruit, nuts 1package (37 g) 11 16 yes no
Milk, 1% fat 1 cup (240 mL) 12 12 no yes
Chocolate milk, 1% fat 1 cup (240 mL) 25 25 yes no
Yogurt, plain nonfat 1 cup (227 g) 18 18 no yes
Yogurt, sweetened 1, fat free, LCS 1 container (170 g) 14 18.5 yes yes
Yogurt, sweetened 2, fat free 1 cup (225 g) 33 33 yes no
Yogurt, sweetened 3, low fat 2.25 oz (64 g) 10 35 yes no
Yogurt, sweetened 4, low fat 4 oz (113 g) 16 32 yes no
Yogurt, sweetened 5, low fat 1 container (113 g) 13 26 yes no
Salad dressing, light 1 2 tbsp (31 g) 2 2 yes yes
Orange juice, 100% 8 fl oz (240 mL) 22 22 no yes
Grape juice, 100% 1 bottle (10 oz) 49 39 no yes
Kidney beans, canned 0.5 cup (130 g) 2 2 yes yes
Peanut butter 2 tbsp (32 g) 3 3 yes yes
Tomato soup, “healthy” 0.5 cup (120 mL) 10 10 yes yes
Tomatoes, canned 0.5 cup (121 g) 3 3 no yes
Stewed tomatoes, canned 0.5 cup (126 g) 7 7 yes yes

NOTE: LCS = low calorie sweetener, LS = labeled serving size, RACC = reference amounts customarily consumed.

a Products followed by numbers represent different brands.

b See Table 7-8 for criteria.

fectioner’s powdered sugar, corn syrup, corn syrup solids, dextrin, fructose, high-fructose corn syrup, honey, invert sugar, lactose, malt syrup, maltose, maple syrup, molasses, nectars (e.g., peach nectar, pear nectar), pancake syrup, raw sugar, sucrose, sugar, white granulated sugar, cane juice, evaporated corn sweetener, fruit juice concentrate, crystal dextrose, glucose, liquid fructose, sugar cane juice, and fruit nectar (USDA, 2010, p. 75).

A selection of example products evaluated against potential qualifying criteria for added sugars is listed in Table 7-9. Peanut butter was included in the analysis even though it exceeded the disclosure/disqualifying level for saturated fat and would be excluded from earning FOP points unless exempted by FDA. Not earning an added sugars point are the following products: Graham and animal crackers; a breakfast bar; sweetened toasted oat cereal; instant oatmeal with added sugars, fruit, and nuts; chocolate-flavored milk; and four sweetened yogurts. Products with added sugars that would earn an FOP point include 100 percent whole wheat bread, a toasted oat cereal, a yogurt sweetened with an added sugar and low calorie sweetener, a light salad dressing, canned kidney beans, peanut butter, a tomato soup that meets the criteria for “healthy,” and canned stewed tomatoes. Because the amount of total sugars would vary among products that qualify for an added sugars point, total sugars in the NFP could be footnoted with a statement such as “Contains no added sugars” or “Contains a qualifying amount of added sugars.” The latter is depicted for 100 percent whole wheat bread in Figures 7-1 through 7-3.

OVERALL PRODUCT EVALUATION

After evaluating a limited number of foods and beverages against current regulations for nutrient content claims, the committee identified potential eligibility and qualifying criteria for individual foods (Table 7-10) and

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-10 Potential Criteria for a Front-of-Package Symbol System for Individual Foods

Nutritional
Component Eligibility Criteriaa Qualifying Criteriab
Saturated fat 4 g per RACC and LS; or per 50 g if RACC is smallc

2 g per RACCd
4.5 g per RACC and per 100 g for seafood and game meatse
3.5 g per RACC for mixed dishes not measurable with a cupf

Trans fat

<0.5 g per LS, or
0.5 g per LS and product does not contain PHVO

Sodium 480 mg per RACC and LS; or per 50 g if RACC is small 480 mg per RACC and LS; or per 50 g if RACC is small
Added sugars Products not categorized as sugars, sweets, and beveragesg “Sugar-free,” “No added sugars,” or total sugars content with specified conditionsh

NOTES: LS, labeled serving, PHVO, partially hydrogenated vegetable oil, RACC, reference amounts customarily consumed. A small RACC is 30 g or 2 tablespoons.

a Products that meet all eligibility criteria may be evaluated for a front-of-package point for saturated and trans fats, sodium, and added sugars.

b Products that meet the qualifying criteria for a given nutritional component earn an FOP point for that component. To earn an FOP saturated and trans fats point, products must meet the qualifying criteria for both fats.

c Some oils, foods containing oils, nuts, foods containing nuts, and seafood and game meats that exceed the saturated fat disclosure/disqualifying level could be exempted based on Food and Drug Administration (FDA)-defined criteria.

d Criteria based on 10 percent Daily Value (DV) to be determined by FDA.

e Saturated fat criteria for “lean” seafood and game meats.

f Saturated fat criteria for “lean” mixed dishes not measurable with a cup.

g USDA Food and Nutrient Database for Dietary Studies (USDA, 2008, pp. 93-100). Examples include regular soda, energy drinks, sports drinks, fruit drinks, candy, sugars, and honey.

h Qualifying sugars criteria include the following:

•   Product meets “sugar free” claim criteria, or

•   Product contains 5 g sugars per LS with no ingredient recognized as added sugars listed in the ingredients statement, or

•   Product meets WIC sugars requirement for breakfast cereals, or

•   Product contains 5 g total sugars per RACC and an ingredient recognized as added sugars except for canned products containing tomatoes and/or other vegetables and yogurt products and substitutes, or

•   Canned products that contain 10 g total sugars per RACC and tomatoes and/or other vegetables that contain naturally occurring sugars as well as an ingredient recognized as added sugars, or

•   Yogurt products and substitutes that contain 20 g total sugars per RACC, a low calorie sweetener, and an ingredient recognized as added sugars. Half the total sugars should come from milk as estimated from the protein and lactose contents of plain yogurt and products expected to be covered by this criterion.

for main dishes and meat products (Table 7-11). The qualifying criteria in general are more restrictive than the eligibility criteria. For example, the eligibility criterion for saturated fat is no more than 4 g per RACC (or per 50 g if the RACC is small), and the qualifying criterion is no more that 2 g per RACC. Thus, products that contain more than 4 g per RACC would not be eligible to receive FOP points, those that contain 4 g or less but more than 2 g per RACC would not qualify for a saturated fat point (but could possibly qualify for sodium and/or added sugars FOP points), and those that contain less than or equal to 2 g per RACC would qualify for a saturated fat point if they also met the criterion for trans fat.

The criteria are not committee recommendations. Rather, the committee views the criteria as starting points for the extensive computer modeling that is needed to determine if the potential criteria are consistent with appropriate ratings for saturated and trans fats, sodium, and added sugars across a wide variety of foods and beverages, main dishes, and meal products. The criteria should balance restrictiveness with practicability. Criteria that are too restrictive may prevent foods and beverages that are consistent with the Dietary Guidelines recommendations and/ or that are WIC-eligible from displaying FOP points, as well as be a disincentive to product reformulation and new product development. For example, it is challenging for many products to meet “low sodium” criteria for a variety of reasons, including consumer acceptance, shelf life, and microbiological safety (IOM, 2010b). Manufacturers may be more motivated to reformulate “high sodium” products to attain the current sodium criteria for “healthy”

TABLE 7-11 Potential Nutritional Criteria for a Front-of-Package Symbol System for Main Dishes and Meal Products

Nutritional Component Eligibility Criteriaa Qualifying Criteriab
Saturated fat 6 g per LS for main dishesc
8 g per LS for meal productsc
4.5 g per 100 g and per LSd
Trans fat 0 g per LS, or
0.5 g per LS and does not contain PHVO
Sodium 720 mg per LS for main dishese
960 mg per LS for meal productse
600 mg per LSe
Added sugars Products not categorized as Sugars, Sweets, and Beveragesf “No added sugars” plus total sugars content with specified conditions to be determined by FDA

NOTES: FDA = Food and Drug Administration, LS = labeled serving size, PHVO = partially hydrogenated vegetable oil.

a Products that meet all eligibility criteria may be evaluated for a front-of-package point for saturated and trans fats, sodium, and added sugars.

b Products that meet the qualifying criteria for a given nutritional component earn an FOP point for that component. To earn an FOP saturated and trans fats point, products must meet the qualifying criteria for both saturated fat and trans fat.

c Disclosure/disqualifying level.

d Saturated fat criteria for lean main dishes and meals.

e Sodium criterion for “healthy” claim.

f USDA Food and Nutrient Database for Dietary Studies (USDA, 2008, pp. 93-100). Examples include regular soda, energy drinks, sports drinks, fruit drinks, candy, sugars, and honey.

than to lower levels that may be unacceptable to consumers. The qualifying amount for sodium could be reduced over time as part of an overall strategy to reduce sodium in the food supply.

Under the two-step approach for evaluating products, manufacturers have two incentives for improving product formulations. One incentive is to lower saturated fat and/or sodium below current FDA disclosure levels to enable the product’s eligibility to earn FOP points. Manufacturers of products potentially eligible for FOP points, i.e., products that do not exceed the FDA disclosure/disqualifying levels for saturated fat and sodium and are not a Sugars, Sweet, or Beverage with added sugars, will have an incentive to formulate products to meet qualifying criteria for saturated and trans fats and/or added sugars and therefore earn FOP points.

Table E-2 (Appendix E) lists the potential FOP points earned for all the example foods and beverages evaluated by the committee; points for the bakery product examples are provided in Table 7-12 for illustrative purposes. The product examples in Appendix E were evaluated against all criteria in Table 7-10 except for the potential qualifying criteria for saturated fat, in which case the criteria for “low saturated fat” were used. The 100 percent whole wheat bread example earned three FOP points. The animal and graham cracker examples earned two FOP points, for saturated and trans fats and for sodium. The snack cracker example also earned two FOP points, one each for sodium and added sugars. The soup cracker example earned no FOP points because its sodium content exceeded the FDA disclosure/disqualifying level for sodium, disqualifying it entirely. If the soup cracker were reformulated to reduce the sodium content to below the disclosure/disqualifying level for sodium, then it would earn three FOP points. The other bakery product examples earned one FOP point, for sodium.

Many of the products listed in Table E-2 that are consistent with dietary recommendations and/or are WIC-eligible would not be eligible to earn FOP points because they exceed the disclosure/disqualifying level for saturated fat and/or do not meet the criteria for “low” saturated fat. This especially was the case for some oils, nuts, foods containing nuts or oils, and salmon, which are relatively lower in saturated fat and higher in mono- and polyunsaturated fats. As suggested in Table 7-10, FDA should consider exemptions and/or alternative eligibility criteria to the saturated fat disclosure/disqualifying level for such products and qualifying criteria for saturated fat based on 10 percent of the DV per RACC. Seafood, including salmon, and game meats could be evaluated for both eligibility and qualification based on criteria for “lean.”

The three 100 percent fruit juices evaluated by the committee would earn three FOP points. These products contain no saturated or trans fats, no or very little sodium, 22 to 39 g of total sugars (all naturally occurring), and

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

TABLE 7-12 Front-of-Package Points for Examples of Bakery Products Evaluated Against Potential Eligibility and Qualifying Criteria

Product SFA/TFAa Sodium Added sugars FOP Points
Bread, 100 percent whole wheat 3
Animal crackers 2
Graham crackers 2
Snack crackers 2
Oat and peanut butter bar 1
Sugar cookies 1
Chocolate chip cookies 1
Toaster pastry 1
Soup crackers (✓) (✓) (✓) 0b

NOTES: SFA = saturated fat, TFA = trans fat.

(✓) = Product would have earned points for SFA/TFA, sodium, and added sugars if it had not been excluded because of sodium content.

a Products were evaluated against the criteria listed in Table 7-10 except that “low saturated fat” was used instead of =2 g per reference amounts customarily consumed.

b Product exceeds the disclosure/disqualifying amount for sodium.

110 to 160 calories per 8 fluid ounces (Table E-1). Concern has been raised about the over-consumption of 100 percent fruit juices, especially among children, because of their high energy content (AAP, 2001, 2006, p. 551). The Dietary Guidelines recommend an increase in fruit intake (p. 34) and recognize that 100 percent fruit juices can be part of a healthy diet; however, because 100 percent fruit juices lack dietary fiber and can contribute extra calories when consumed in excess, the Dietary Guidelines recommend that the majority of the fruit come from whole fruit (USDA, 2010, p. 36). The declaration of calorie content on the FOP will help consumers recognize the high energy content of 100 percent fruit juices.

Concern also has been raised about the added sugars content of breakfast cereals marketed to children (Batada et al., 2008; Bell et al., 2009), and the committee recognized that some FOP systems have been criticized in relation to their rating of sugar-sweetened cereals. With the FOP system proposed by the committee, consumers will be able to quickly distinguish among cereals. Cereal manufacturers have gradually reduced the amount of added sugars in cereals advertised to children. Specifically, the sugar content in many cereals has been reduced from 12 to 15 grams to 10 or 11 grams per serving, and some manufacturers have indicated their intent to reduce added sugars to below 10 grams.Table E-3). Although not earning an added sugars point, the three cereals would earn two FOP points, one for saturated and trans fats and one for sodium.

ALIGNMENT WITH THE REGULATORY ENVIRONMENT

Points for saturated and trans fats, sodium, and added sugars that are displayed in a FOP symbol system would be implied nutrient content claims.25 However, the eligibility and qualifying criteria for the FOP system described in this chapter are not entirely consistent with current regulations for nutrient content claims. Some, but not all, of these inconsistencies are discussed below. As it develops and tests an FOP symbol system, FDA will need to address inconsistencies between potential criteria and current regulations in addition to performing

image

24 The Children’s Food & Beverage Advertising Initiative in Action: A Report on Compliance and Implementation During 2009, p. 9. Available online: http://www.bbb.org/us/storage/0/Shared%20Documents/BBBwithlinks.pdf (accessed July 7, 2011).

25 21 CFR 101.13(b)(2).

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

extensive computer modeling to assess a variety of foods and beverages, main dishes, and meal products against potential eligibility and qualifying criteria.

As an example of inconsistency between the proposed criteria and current regulations, saturated fat and sodium disclosure/disqualifying levels are eligibility criteria only when used as disqualifying amounts for health claims. When pertaining to nutrient content claims, foods that exceed disclosure/disqualifying levels are only required to bear a statement disclosing that the nutrient exceeding the specified level is present in the food, e.g., “See nutrition information for [saturated fat and/or sodium] content.”

Other inconsistencies include that current FDA regulations for nutrient content claims for individual foods are consistent across all product categories, e.g., the criteria for “low saturated fat” are the same for breakfast cereals, grain-based desserts, dairy products, vegetable oils, salad dressings, nuts, and seafood. As such, nutrient content claims for saturated fat do not provide exemptions for oils, nuts, foods containing oils and nuts, or certain types of seafood (e.g., salmon)—foods whose consumption is recommended by the Dietary Guidelines. Current regulations for saturated fat claims also do not require a product to contain less than 0.5 g trans fat per labeled serving; however, they do require declaration of the amount of monounsaturated and polyunsaturated fats in the NFP and thus provide a source of such information for consumers.

Current FDA regulations for “no added sugars” do not make exemptions for otherwise healthful foods that contain a small amount of added sugars, such as WIC-eligible breakfast cereals, whole wheat bread, peanut butter, and canned vegetables, or for yogurts that contain both added sugars and a low calorie sweetener. “No added sugars” and the amount of total sugars per labeled serving are not qualifying criteria for saturated fat or sodium content claims; nor are entire categories of foods and beverages excluded from making saturated fat or sodium content claims because of added sugars content.

In order for the FOP symbol to appear on as many products as possible, a similar approach for evaluating foods containing saturated fats or sodium, e.g., meat and poultry products should be assessed. In doing so, USDA would need to address some regulatory issues that currently deviate from FDA’s regulations. For example, USDA does not currently require trans fat to be listed on nutrition labels, but information on the amount of trans fat in a serving is needed to determine whether a product exceeds the qualifying criteria. In addition, because USDA regulations do not include disclosure/disqualifying levels, regulations to implement an FOP symbol system would need to include those or other such levels determined by the agency to be appropriate for setting eligibility and qualifying criteria.

Finally, as with all regulatory actions, public input must be solicited on an FOP symbol system and its nutritional criteria.

SUMMARY AND CONCLUSIONS

This chapter described the characteristics of a model FOP symbol system and presented an approach for developing criteria for and evaluating the amount of saturated and trans fats, sodium, and added sugars in foods and beverages consistent with these characteristics. Successful FOP symbol systems do not provide specific nutrient information but rather offer consumers guidance based on that information and give some idea of the healthfulness of the choice on an ordinal scale. Because of public concern about overweight and obesity, an FOP symbol system should display calories per serving expressed in a common household measure consistent with the NFP. Criteria for evaluating products for saturated and trans fats, sodium, and added sugars content should proceed in a two-step process:

1.  Determine whether a product may earn FOP points, based on eligibility criteria that determine whether the product contains an amount of one or more of the stated nutrient components that is not consistent with the Dietary Guidelines recommendations. If a product’s level of even one nutrient component exceeds the criteria threshold, then the product is ineligible for FOP points and would carry only calories per serving size.

2.  Determine whether a product that meets the eligibility criteria earns FOP points for one or more of the following: saturated and trans fats, sodium, and/or added sugars based on qualifying criteria that assess acceptably low amounts.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

BOX 7-3
Limitations Associated with Criteria for Limits on Nutrient
Components in a Front-of-Package (FOP) Symbol System
Based on Current Regulations and Potential Solutions

Saturated Fat

•   Disclosure/disqualifying level as the basis for exclusion from earning FOP points is too restrictive for many products that are consistent with the Dietary Guidelines recommendations and/or are eligible for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). A solution would be to exempt certain products from Food and Drug Administration (FDA)-based eligibility criteria.

•   “Low” criteria as the basis for qualifying for an FOP point are too restrictive for most product categories, especially products that are consistent with the Dietary Guidelines recommendations and/or are WIC-eligible. A solution would be to develop qualifying criteria based on 10 percent Daily Value (DV) per Reference Amounts Customarily Consumed (RACC) for individual foods and on “lean” for seafood and game meats.

•   Examples of products that are adversely affected by the disclosure/disqualifying level and/or criteria for “low” include some oils, nuts, foods containing oils and nuts (such as salad dressings, mayonnaise, soft margarines, and peanut butter), 1 percent milk, eggs, and salmon.

Trans Fat

•   No regulatory criteria exist for “low” or “high” amounts. A solution would be to qualify products based on the trans fat declared in the Nutrition Facts panel and the absence or presence of a partially hydrogenated vegetable oil in the ingredients list.

Sodium

•   “Low sodium” criteria are overly restrictive as qualifying criteria for most products on the market. A solution would be to qualify products based on “healthy” criteria.

•   For individual foods, there is no gap between the FDA disclosure/disqualifying levela and the “healthy” criteria.b As a result, “healthy” may appear too lenient as a qualifying criterion, at least for some products. This is not the case for main dishes and meal products, which have a significant gap between disclosure and “healthy” levels. A solution for individual foods would be to lower the criteria for “healthy” as a national sodium reduction initiative proceeds.

Added sugars

•   No regulatory criteria exist for “low” or “high” amounts, and no analytical methods are available for monitoring compliance. Evaluation must rely on claim criteria for “sugar free” and “no added sugars” as well as the amount of total sugars declared in the Nutrition Facts panel in conjunction with food specifications.

•   100 percent fruit juices do not contain added sugars but do contain a relatively high amount of naturally occurring sugars, and juices can contribute to extra calories when consumed in excess. FOP declaration of calories will help to make consumers aware of the high energy content, even as the FOP points indicate the juices to be a relatively healthy beverage.

•   Presweetened cereals that do not meet the WIC sugar requirement could earn up to two FOP points, one for saturated and trans fats and one for sodium. Consumers will be able to identify cereals that do and do not earn an FOP point for added sugars.

image

a Sodium disclosure/disqualifying level is >480 mg per RACC and labeled serving (LS), or per 50 g if RACC is small.

b Sodium “healthy” criteria is 480 mg per RACC and LS, or per 50 g if RACC is small.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
×

The criteria for evaluating nutrients to limit through an FOP symbol system should be based on FDA labeling requirements and therefore transparent and nonproprietary and the FOP symbol system should be integrated with the NFP so the two can be mutually reinforcing. Current FDA regulations will require modifications and/or exemptions, and new regulations will need to be developed along with food group specifications to find an appropriate balance between restrictiveness and practicality. The approach described in this chapter has strengths and limitations (listed in Box 7-2 and Box 7-3). No one FOP symbol system, including its underlying nutrition criteria, is flawless. Nonetheless, the committee believed that development of an FOP symbol system based on the model and approach described here can be achieved, with extensive computer modeling and solicitation of public input.

REFERENCES

AAP (American Academy of Pediatrics, Committee on Nutrition). 2001. The use and misuse of fruit juice in pediatrics. Pediatrics 107:1210-1213.

AAP. 2006. Dietary recommendations for children and adolescents: A guide for practitioners. Pediatrics 117:544-559.

ARS (Agricultural Research Service, U.S. Department of Agriculture). 2008. USDA Food and Nutrient Database for Dietary Studies, 3.0. Available online: http://www.ars.usda.gov/services/docs.htm?docID=12089 (accessed May 19, 2011).

Batada, A., M. Dock Seitz, M. G. Wootan, and M. Story. 2008. Nine out of 10 food advertisements shown during Saturday morning children’s television programming are for foods high in fat, sodium, or added sugars, or low in nutrients. Journal of the American Dietetic Association 108:673-678.

Bell, R. A., D. Cassady, J. Culp, and R. Alcalay. 2009. Frequency and types of foods advertised on Saturday morning and weekday afternoon English- and Spanish-language American television programs. Journal of Nutrition Education and Behavior 41:406-413.

Hasher, L., and R. T. Zacks. 1984. Automatic processing of fundamental information: The case of frequency of occurrence. American Psychologist 39:1372-1388.

IOM (Institute of Medicine). 2005. Dietary Reference Intakes for Energy, Carbohydrate, Fiber, Fatty Acids, Cholesterol, Protein, and Amino Acids. Washington, DC: The National Academies Press.

IOM. 2010a. Front-of Package Nutrition Rating Systems and Symbols: Phase I Report. Washington, DC: The National Academies Press.

IOM. 2010b. Strategies to Reduce Sodium Intake in the United States. Washington, DC: The National Academies Press.

Romaniuk, J., and B. Sharp. 2004. Conceptualizing and measuring brand salience. Marketing Theory 4:327-342.

USDA (U.S. Department of Agriculture). 2008. Food and Nutrient Database for Dietary Studies, 3.0. Beltsville, MD: U.S. Department of Agriculture, Agricultural Research Service, Food Surveys Research Group.

USDA. 2010. Dietary Guidelines for Americans. Washington, DC: U.S. Government Printing Office.

USDA. 2011. Dietary Guidelines for Americans, 2010. Available online: http://www.cnpp.usda.gov/DGAs2010-PolicyDocument.htm (accessed April 2, 2011).

Wixted, J. T. 2004. The psychology and neuroscience of forgetting. Annual Review of Psychology 55:235-269.

Suggested Citation:"7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients." Institute of Medicine. 2012. Front-of-Package Nutrition Rating Systems and Symbols: Promoting Healthier Choices. Washington, DC: The National Academies Press. doi: 10.17226/13221.
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During the past decade, tremendous growth has occurred in the use of nutrition symbols and rating systems designed to summarize key nutritional aspects and characteristics of food products. These symbols and the systems that underlie them have become known as front-of-package (FOP) nutrition rating systems and symbols, even though the symbols themselves can be found anywhere on the front of a food package or on a retail shelf tag. Though not regulated and inconsistent in format, content, and criteria, FOP systems and symbols have the potential to provide useful guidance to consumers as well as maximize effectiveness. As a result, Congress directed the Centers for Disease Control and Prevention (CDC) to undertake a study with the Institute of Medicine (IOM) to examine and provide recommendations regarding FOP nutrition rating systems and symbols.

The study was completed in two phases. Phase I focused primarily on the nutrition criteria underlying FOP systems. Phase II builds on the results of Phase I while focusing on aspects related to consumer understanding and behavior related to the development of a standardized FOP system.

Front-of-Package Nutrition Rating Systems and Symbols focuses on Phase II of the study. The report addresses the potential benefits of a single, standardized front-label food guidance system regulated by the Food and Drug Administration, assesses which icons are most effective with consumer audiences, and considers the systems/icons that best promote health and how to maximize their use.

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