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7 A Model Front-of-Package Symbol System Including Criteria for Evaluating Nutrients
Pages 71-96

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From page 71...
... 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.
From page 72...
... 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: • s imple, understanding does not require specific or sophisticated nutritional knowledge; • i nterpretive, nutrition information is provided as guidance rather than as specific facts; • o rdinal, nutritional guidance is offered through a scaled or ranked approach; and • s upported by communication with readily remembered names or identifiable symbols.
From page 73...
... 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.
From page 74...
... 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.
From page 75...
... (168g) Product 150 190 100 150 calories calories calories calories per 16 chips per 1 Cup per slice per bar System Detail Nutrition Facts POTATO CHIPS OAT AND PEANUT BUTTER BAR RAISIN BRAN FLAKES 100% WHOLE WHEAT BREAD UNIT PRICE UNIT PRICE UNIT PRICE UNIT PRICE $ $ $ $ 0.23 0.36 0.13 0.19 $ $ $ $ PER OUNCE PER OUNCE PER OUNCE PER OUNCE 150 150 190 100 calories calories calories calories per 16 chips per bar per 1 Cup per slice 1.50 2.50 3.39 4.49 Shelf Tag FIGURE 7-1 Front-of-package symbol system example 1.
From page 76...
... (168g) Product calories per 16 chips calories per 1 cup calories per bar calories per slice 150 190 150 100 System Detail Nutrition Facts POTATO CHIPS OAT AND PEANUT BUTTER BAR RAISIN BRAN FLAKES 100% WHOLE WHEAT BREAD UNIT PRICE UNIT PRICE UNIT PRICE UNIT PRICE $ $ $ $ calories per 16 chips calories per 1 cup calories per bar calories per slice 150 190 150 100 0.23 0.36 0.13 0.19 $ $ $ $ PER OUNCE PER OUNCE PER OUNCE PER OUNCE 1.50 2.50 3.39 4.49 Shelf Tag FIGURE 7-2 Front-of-package symbol system example 2.
From page 77...
... (168g) Product 100 190 150 150 calories calories calories calories per slice per 1 cup per bar per 16 chips System Detail Nutrition Facts POTATO CHIPS OAT AND PEANUT BUTTER BAR RAISIN BRAN FLAKES 100% WHOLE WHEAT BREAD UNIT PRICE UNIT PRICE UNIT PRICE UNIT PRICE $ $ $ $ 190 150 150 0.23 0.36 0.13 0.19 $ $ $ $ calories calories calories calories PER OUNCE PER OUNCE PER OUNCE PER OUNCE per slice per 1 cup per bar per 16 chips 1.50 2.50 3.39 4.49 100 Shelf Tag 77 FIGURE 7-3 Front-of-package symbol system example 3.
From page 78...
... 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)
From page 79...
... 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.
From page 80...
... exceed the disclosure level for saturated fat. • ost foods, including those that are consistent with the recommendations of the Dietary Guidelines M for Americans or that are WIC-eligible, do not meet criteria for "low saturated fat." • o disclosure level or regulatory criteria defines "low" for trans fat.
From page 81...
... 21) , R02048 trans fat content can be evaluated when determining a product's whether it qualifies for an FOP point for saturated and trans fats (see Qualifying Criteria for FOP Points)
From page 82...
... 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.
From page 83...
... 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.
From page 84...
... 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.
From page 85...
... 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.
From page 86...
... 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)
From page 87...
... ≤140 mg per 100 g ≤600 mg per LS Main dishes and meal products NOTES: LS = labeled serving size, RACC = reference amounts customarily consumed. A small RACC is ≤30 g or ≤2 tablespoons.
From page 88...
... 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.
From page 89...
... 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)
From page 90...
... 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)
From page 91...
... 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)
From page 92...
... 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.
From page 93...
... "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.
From page 94...
... • resweetened cereals that do not meet the WIC sugar requirement could earn up to two FOP P 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.
From page 95...
... 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)


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