by Marion Nestle
Oct 20 2011

IOM releases tough report on front-of-package labeling

The Institute of Medicine (IOM) just released its second report on front-of-package (FOP) labeling.  It tells FDA to allow only four items in any front-of-package evaluation scheme:

  • Calories
  • Saturated and trans fat
  • Sodium
  • Sugars

To display this, the IOM committee recommends a point system based on levels of saturated and trans fats, sodium, and sugars for evaluating food products.  The points are to be indicated with check marks or stars.  Here is an example of how stars might be used to indicate products that qualify for zero, one, two, or three points.

I’m guessing that anything this clear and understandable will elicit storms of protest.

Recall that food companies have been setting their own nutrition criteria for evaluating their very own products and identifying the “better-for-you” or “more nutritious” products with special front-of-package logos.  By company standards, many of their products qualify for the logos.

To deal with the multiplicity and absurdity of such schemes, the FDA asked the IOM to take a look at the various FOP logos that were out there and recommend how to clean up the mess.  The first IOM report said the FDA should allow FOP labels to state only calories, saturated and trans fat, and sodium, but not sugars (this last was a mistake, I thought).

But—while the FDA was waiting for the IOM to produce its next report, the Grocery Manufacturers Association (GMA) and Food Marketing Institute (FMI) jumped the gun.  Their preemptive logo included “positive” nutrients such as vitamins and fiber along with the “negatives.”  This scheme is already in use on food packages.

The IOM committee was faced with an impossibly difficult task: to come up with a front-of-package scheme that would reduce the overall nutritional quality of processed foods to the sum of a few key factors.

Given strong industry marketing pressures to retain front-of-package labels—and the lack of an option to remove them altogether—the committee did the best it could with an inherently bad idea.

Why a bad idea?  FOP labels are a tool for selling, not buying.  They make highly processed foods look healthier, whether or not they really are.

And whether slightly better-for-you processed foods assessed by this method will help anyone to make better food choices and to be healthier remains open questions.

Nevertheless, the IOM proposal is a huge improvement over what food companies are now doing.  I consider it courageous.

Why courageous?  Because the scheme makes it so easy to distinguish products that qualify for the various point levels.

For example, here are some products that qualify for stars:

  • Toasted oat cereal
  • Oatmeal, instant
  • Milk, 1% fat
  • Yogurt, plain nonfat
  • Salad dressing, light
  • Orange juice, 100%
  • Grape juice, 100%
  • Kidney beans, canned
  • Peanut butter
  • Tomato soup, “healthy”
  • Tomatoes, canned

Examples of products that do not qualify:

  • Animal crackers
  • Graham crackers
  • Breakfast bar
  • Sweetened toasted oat cereal
  • Oatmeal, instant with fruit, nuts
  • Chocolate milk
  • Yogurt, sweetened

I can’t wait to see the GMA and FMI press release on this report.

And the FDA must now take this report under consideration to begin its interminable rulemaking process.

Why, you might ask, does any of this matter?  Aren’t questions about what food companies put on package labels basically trivial?  Don’t FOP label fights divert attention from other, more important food issues?

Maybe, but I see this as a test of the FDA’s authority to regulate and set limits on any kind of food industry behavior.  If the FDA cannot mandate a label that might help consumers choose healthier food options or refuse to permit labels that mislead consumers, it means the public has little recourse against any kind of corporate power.

I think this matters, and I’ll bet food companies do too.

And now, sit back and watch the lobbying begin!

That did not take long:  Here’s the GMA press release—fairly tame all things considered:

The Institute of Medicine’s Committee on Examination of Front-of-Package Nutrition Rating Systems and Symbols report adds a perspective to the national dialogue about front-of-pack nutrition labeling.  In the meantime, food and beverage companies have developed a real-world program that delivers real value to real consumers in real time.

Consumers have told us that they want simple and easy to use information and that they should be trusted to make decisions for themselves and their families. The most effective programs are those that consumers embrace, and consumers have said repeatedly that they want to make their own judgments, rather than have government tell them what they should and should not eat.  That is the guiding principle of Facts Up Front, and why we have concerns about the untested, interpretive approach suggested by the IOM committee.

My translation: Consumers prefer to have the food industry’s “Facts Up Front” tell them what to eat?  I don’t think so.







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  • Natural Grocers

    You insight is correct, Marion. Smart consumers look to the full ingredient list first, and specifically ignore manipulated front-of-pack shortcuts

    Vitamin Cottage Natural Food Markets, Inc. (“Natural Grocers) conducted a survey of 200 consumers to help the FDA understand the usefulness of front-of-pack nutrition labels.

    Highlights from the Survey:

    –Most front-of-pack nutrition labeling has a neutral affect on health-conscious consumers’ perceptions of healthiness of food.

    –Health-concious consumers rely primarily on the Ingredients list and somewhat on the Nutrition Facts label to determine healthiness of foods.

    –Health-concious consumers have specific ingredients that can cause a food to be rated unhealthy, no matter what other healthy attributes the food has.

    –Certain front-of-pack labels provide respondents with high correlation to healthiness, including “No GMOs,” “USDA Organic,” and “No Preservatives.”

    View the full survey results here:

  • Kathaleen Briggs Early PhD, RD, CDE

    This is fantastic news, in my opinion. Average consumers are generally confused by today’s food labels and nutrition facts panel. I cannot count the times patients have told me they buy a product thinking it’s a healthy choice, when in reality it’s not (e.g.,”HiC – it’s high in vitamin C, isn’t it? Isn’t that good? I have diabetes and heard vitamin C is good for people with diabetes.”) It provides little help to those with literacy challenges. The IOM approach is a welcomed simple method — now if we can only get the food manufacturer’s to accept the IOM suggestions.

  • Kathaleen Briggs Early PhD, RD, CDE

    Good grief, Facts Up Front only adds to consumer confusion in my experience.

    GMA: I beg you — please do what is right here. Take the suggestions of the IOM and the nutrition/public health experts. A star rating system requires NO math, NO reading and is a rating system all are familiar with. You make the products — healthy and not healthy — own it fully. Let the consumers choose, without the confusion of all the numbers and readings current labels and “Facts Up Front” require. You can become a partner in improving America’s health and reducing obesity and other chronic disease, which will in turn reduce health care costs and save lives and dollars. You will hailed as public health heroes. Seriously.

  • Chris

    There has been a similar thing adopted here in the UK which has been running for a couple of years now. it is called the traffic light system and I think it is a little simpler to read at a glance than the proposed IOM system.

    The traffic light system basically shows red, green or amber at the front of a package. If there is red it means that the product has plenty of something which not particularly healthy and green means good content of course, this is combined with a figure and the name of the ingredient in question. It is set out in a sort of pie chart. I think it works pretty well and is easy to understand at a glance.

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  • Andrew @ Eating Rules

    1. We’d be better off if we simply eliminated ALL marketing and language on the front of packages, with the exceptions of the name of the product and the amount in the package.

    2. If we’re going to have a system that reduces it to these few key metrics, I think it would have been better for them to judge products on naturally-occurring fiber content instead of saturated or trans fats. Foods high in fiber are generally going to be low in saturated fats, so it solves two problems in one.

  • Margeretrc

    I don’t buy much in the way of processed foods, but when I do, I only look for three things: Ingredients, total carbohydrates, and fiber and I don’t care if it is on the front of the package or the back, as long as it is somewhere. Beyond that, I could care less. I would not want to see any labeling system that did not include at least that much information, for if I have that, I can decide for myself whether the item is healthy or not–I don’t need some government agency to tell me as their criteria aren’t necessarily mine anyway. The GMA is not wrong–there are plenty of us who want to make our own decisions and need “just the facts, Ma’am, just the facts.”

  • Charlie L

    My initial impression is that IOM’s proposal seems similar in concept to the Energy Star rating system in that the specifications of the appliance or machine is interpreted for the consumer in an easy-to-understand manner–i.e. 4 stars are better than 3, and so on.

    But what kind of nutrition regime would be promoted in such a system for food? A low-fat, high-carb approach has been a popular one the last few decades. A low-carb, high-fat approach is one I follow. Is vegetable oil good? Given the various ideas about what’s healthy and a million diets on the market, how would one choose which foods are “nutritious”?

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  • Tim Rebori

    Thank you for the direct post. I appreciate information in the article. As an owner of a drug testing lab in Kansas City, the more information and articles I come across that I can share with my staff the better off I am in helping the community we serve.

  • Margeretrc

    @Charlie L, You can be sure it will be a low fat, high carb regime that will be promoted in such a labeling system. Like you, I follow a low carb, high fat regime and I am also not interested in consuming any vegetable oil, so none of this newfangled labeling will be of any use to us. But as long as they don’t stop listing ingredients and providing the usual nutritional information on the back, I don’t much care what else they do.

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  • Kathaleen Briggs Early, PhD, RD, CDE

    Study: Why People Don’t Read Nutrition Labels

    How often do you look at the Nutrition Facts label on the side of the box? A new study reveals that people say they look at it a lot more than they actually do.

    Read more:

  • Chris McNabb

    Thank you for the fact filed information. When the government and the entities that direct the labeling, and then we teach people HOW to read it and what it all means, we may start to see this epidemic of Childhood obesity start to stem. It isn’t enough to label our food but to educate and teach people what it all means to them and their health.

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  • Cuong

    The proposed star rating was a bit disappointing because it required too much explaining. I am surprise the IOM did not recommend some form of the traffic light rating used in the UK. A study released by the Obesity Policy Coalition found that over 80% of Australian consumers prefer the traffic light system. There’s even an app for it! Now that’s just too cool.

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  • PmoraRD

    While scientists cannot predict whether consumers will actually choose healthier foods if labeling laws change they do believe that good, useful information as a means to educate, will enable consumers to make informed choices.
    Studies show that consumers need significantly less time to evaluate simple front-of-pack labeling compared to the more complex labeling format. However, the multitude of different front-of-pack (FOP) labeling formats available, mostly fail to clearly identify less-healthy foods and instead attract consumers towards products with supposedly better profiles.
    While I commend the IOM for creating such a clear and understandable document, I agree with @Chris and @Cuong. A survey carried out in 2006 by the consumer organization Which? found that 73% of consumers felt that having a variety of different labeling schemes was confusing. However, while testing the performance of different labeling methods using examples of real food products, the same organization found that the traffic light food labeling system worked best for consumers looking to assess nutrient levels in a given product as well as compare between multiple products. (Read more: (Accessed May 2012). Results from another study supported this idea, indicating that consumers using the traffic light labeling system were three to five times more likely to identify the healthier food product than those using two other systems. The same study presented strong evidence regarding the effectiveness of this system to allow consumers, particularly those in lower socioeconomic status that are more at risk for obesity, to make healthier food choices. (Read more: McLaren, L. Socioeconomic status and obesity. Epidemiological Review. 2007; 29: 29–48)
    @Andrew@Eating Rules: I agree with your first statement as the overall effectiveness of a new labeling system strongly depends on the elimination of multiple confusing labeling schemes. However, I also believe cohesive presentation of nutrition information across all food products in its place can allow for consumers to more readily compare the information provided.

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