by Marion Nestle

Currently browsing posts about: Labels

Nov 16 2015

FDA is taking comments on “natural”

I’m always indebted to Food-Navigator-USA for spot-on commentary on current food politics.  Here, for example, is Elaine Watson on the FDA’s amazing decision to take comments on the meaning of “natural” on food labels.

Having studiously avoided this food labeling minefield for years, the Food and Drug Administration (FDA) has surprised many in the trade by seeking comments on the definition of a word that has launched a thousand class action lawsuits (well almost): ‘natural’.

Her piece is worth reading for its excellent reporting and interviews with industry stakeholders.

About “natural,” the FDA has said:

From a food science perspective, it is difficult to define a food product that is ‘natural’ because the food has probably been processed and is no longer the product of the earth. That said, FDA has not developed a definition for use of the term natural or its derivatives. However, the agency has not objected to the use of the term if the food does not contain added color, artificial flavors, or synthetic substances.

Now petitions have induced the FDA to seek comments, the first step in its standard rulemaking processes.

Specifically, the FDA asks for information and public comment on questions such as:

—Whether it is appropriate to define the term “natural,”

—If so, how the agency should define “natural,” and

—How the agency should determine appropriate use of the term on food labels.

“Appropriate” in this context translates as:  Should high fructose corn syrup be considered “natural?” (The FDA said yes in 2008).   How about GMOs? (the FDA’s position on GMOs is that they are not materially different from any other kind of food).

To file comments on these and other questions,

  • For electronic submissions, go to and search for docket number FDA-2014-N-1207.
  • For submissions by mail, use the following address. Be sure to include docket number FDA-2014-N-1207 on each page of your written comments.  Division of Dockets Management, HFA-305, Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD 20852
Sep 9 2015

Creative food packaging: An example from China

I thought we all needed a break from the debates over funding of science by the GMO industry and the organic industry.

How’s this for supermarket creativity!


Maybe if the Soviets had used a Tomahawk instead of a sickle?

Thanks to Maya Joseph for sending me this photo sent to her by Lillian Chou in China.

Jul 24 2015

Good news: FDA proposes Daily Value for Added Sugars–10% of calories

The FDA announced this morning that it is proposing a Daily Value (the maximum) for Added Sugars on food labels—10% of calories.

Susan Mayne, FDA’s Director of the Center for Food Safety and Applied Nutrition, explains the rationale: this is the percentage recommended by the Dietary Guidelines and practically every other health authority that has examined the evidence on sugars and health.

Ten percent of calories means 200 calories on a 2000 calorie daily diet, or 50 grams, or 12 teaspoons—the amount in one 16-ounce soda.

If you drink a 16-ounce soda, you have done your added sugars for the day.

If this seems abstemious, consider that 10% of calories is more generous than the amount recommended by the UK’s Scientific Advisory Committee on Nutrition:

It is recommended that the average population intake of free sugars should not exceed 5% of total dietary energy for age groups from 2 years upwards.

The World Health Organization’s recent report on sugars and health also views 10% as the absolute maximum:

  • In both adults and children, WHO recommends reducing the intake of free sugars to less than 10% of total energy intake (strong recommendation).
  • WHO suggests a further reduction of the intake of free sugars to below 5% of total energy intake (conditional recommendation).

The WHO report explains:

The recommendation to further limit free sugars intake to less than 5% of total energy intake, which is also supported by other recent analyses, is based on the recognition that the negative health effects of dental caries are cumulative, tracking from childhood to adulthood…No evidence for harm associated with reducing the intake of free sugars to less than 5% of total energy intake was identified.

Americans, on average, consume way more than 10% of calories from added sugars, so this recommendation means a sharp restriction.

It means consuming less of sugary products: sodas, baked goods, and all those packaged foods with added sugars.

The proposal is up for comment.

You can bet that there will be plenty.

Congratulations to the FDA for this one.  Let’s hope it sticks.

How to Comment

To comment on the proposed changes to the Nutrition Facts Label:

  1. Read the proposed changes.
  2. Starting Monday, July 27, 2015, go to to submit comments.
Apr 22 2015

Vermont’s new GMO labeling regulations

Vermont has issued GMO labeling rules.  They seem straightforward.  Here are the ones that I think matter:

1.  Unpackaged GMO foods must post labels

  • Raw: “produced with genetic engineering.”
  • Processed: “produced with genetic engineering,” or “may be produced with genetic engineering.”

2.  Packaged GMO foods must be labeled by the manufacturer

  • Raw: “produced with genetic engineering”
  • Processed: “produced with genetic engineering,” or “partially produced with genetic engineering” (<75% GMO) or “may be produced with genetic engineering (if they aren’t sure).”

3.  If the food is GMO, it cannot be labeled “natural”

4.  The font can’t be any smaller that of Serving Size in the Nutrition Facts label

It’s hard for me to imagine why the biotechnology industry, Grocery Manufacturers Association, and so many food companies think that saying “may be produced with genetic engineering” means the end of civilization as we know it, so much so that they pour millions of dollars into fighting it.


Now they are taking Vermont to court to try to block implementation of these rules.

Otherwise, the rules go into effect July 1, 2016.

That will be fun to see!





Nov 7 2014

Weekend reading: health food regulation

Jill Hobbs, Stavroula Malla, Eric Sogah, and May Yeung.  Regulating Health Foods: Policy Challenges and Consumer Conundrums.  EE Edward Elgar Publishing, 2014.

I did a blurb for this one:

Regulating Health Foods systematically organizes the widely disparate definitions, regulations, and policies used internationally to govern functional foods, supplements and nutraceuticals, and does so from the standpoint of the industry and its regulators.  Food scientists, regulators, and industry professionals will especially appreciate its detailed international perspective.

This is a book for policy wonks and students who want to find out how various countries regulate food labels, or who would llike to know such things as how Codex Alimentarius guidelines apply to health claims.  The authors, who work at Canadian Universities, have pulled together vast amounts of detailed information about label regulations by country, with commentary.  Here is an example:

Japan currently provides an interesting mix between a purely generic system and a purely product-specific one.  Although the system is decidedly more product-specific.  Standardized FOSHU [Food for Specific Health Uses] lowers the costs to individual firms seeking claims on ingredients with well-established ingredient-health effect relationships.  At the same time, there are potentially significant returns to investment for firms wishing to market a new product with health benefits.

Aug 27 2014

On two views of GMOs: Michael Specter vs. Vandana Shiva and Gary Hirshberg

Michael Specter’s article “Seeds of Doubt” in the current issue of The New Yorker  is a critical profile of  India’s Vandana Shiva and her active opposition to genetically modified foods.  At the end, it offers this somewhat temporizing statement:

Genetically modified crops will not solve the problem of the hundreds of millions of people who go to bed hungry every night. It would be far better if the world’s foods contained an adequate supply of vitamins. It would also help the people of many poverty-stricken countries if their governments were less corrupt. Working roads would do more to reduce nutritional deficits than any G.M.O. possibly could, and so would a more equitable distribution of the Earth’s dwindling supply of freshwater. No single crop or approach to farming can possibly feed the world. To prevent billions of people from living in hunger, we will need to use every one of them.

Despite this peace offering, his article elicited a firm rebuttal from Dr. Shiva. It also elicited a rebuttal from Gary Hirshberg, chair of Just Label It. If you want to get into the weeds of the GMO arguments, all three of these pieces are well worth reading.

They raise and debate the same arguments I discussed in Safe Food: The Politics of Food Safety, first published in 2003 and out in a second edition in 2010. As I explain in the book, the gist of the arguments comes from two apparently irreconcilable views of GMO foods:

  1. The “science-based” position: If GMOs are safe (which they demonstrably are), there can be no rational reason to oppose them.
  2. The “societal value-based” position: Even if GMOs are safe (and this is debatable), there are still plenty of other reasons to oppose them.

Specter holds the first position.  Shiva and Hirshberg hold the second. Those who hold the “science-based” position would do well to take societal values more seriously.

Seed patents, monoculture, weed resistance, and other such concerns trouble people who care about food systems that promote health, protect the environment, and provide social justice.

Labeling, right from the start, would have acknowledged the importance of such values. Until GMO foods are labeled as such, the same arguments are likely to go on endlessly, with no reconciliation in sight.


Aug 18 2014

Food Navigator on what’s happening with the nutrition label

Food Navigator—USA’s Elaine Watson just put together a special edition on the revamping of the Nutrition Facts label.  Her title: Radical overhaul or a missed opportunity?

To understand what’s happening with food labels, you can start with the FDA’s home page on its proposed revisions.  The comment period has ended.  You can read the comments that have been filed on the Nutrition and Supplement Facts panels, and those filed on the proposed changes to the standards for serving sizes.  These are fun to read; opinions, to say the least, vary.

But back to Food Navigator, which collects in various pieces on the topic in one place.  The “Radical overhaul” piece contains a summary of the major provisions.  Others in the series are also useful (I’m quoted in some of them):

Does vitamin D belong on the Nutrition Facts panel?

FDA proposals to list “added sugars” on the Nutrition Facts panel have already generated heated debate, so it’s perhaps unsurprising that its plan to include vitamin D is proving equally controversial…

Should ‘added sugars’ be listed on the Nutrition Facts panel?

A row is brewing over the merits of including ‘added sugars’ on the Nutrition Facts panel, with critics arguing that our bodies don’t distinguish between ‘naturally occurring’ and ‘added’ sugar – and neither should food labels – and supporters saying it will help consumers identify foods with more empty calories.

 Nutrition Facts overhaul is a missed opportunity for long chain omega-3s EPA and DHA, says GOED

The FDA’s overhaul of the Nutrition Facts panel misses a public health opportunity by prohibiting firms from even highlighting long chain omega-3 fatty acids EPA and DHA on the panel, says GOED.

What are the biggest contributors of added sugars to the US diet?

Check out this analysis of NHANES data to see where our added sugars are coming from plus read new comments about the ‘added sugars’ labeling proposal from Ocean Spray cranberries and others.

Former FDA commissioner: Nutrition Facts overhaul doesn’t go far enough

FDA proposals to overhaul the Nutrition Facts panel on food labels don’t got far enough, says former FDA commissioner David Kessler, M.D.

Behavioral scientists: Changing serving sizes on Nutrition Facts label could have unintended consequences

FDA proposals to change the way serving sizes are calculated to better reflect real-life eating behavior could encourage some people to eat even more unless the wording is changed, says one expert group.

Until phosphorus gets on the USDA’s radar, labeling policy won’t change: NKF

While phosphorus is an essential nutrient found naturally in some foods such as egg yolk and milk, it is increasingly added to packaged foods via a raft of phosphorus additives, and some experts believe it should be listed on the Nutrition Facts panel.

Canada’s proposed Nutrition Label changes emphasize calories, sugar

Health Canada is proposing changes to nutrition labels that would make them easier for consumers to read.

RD: There’s a health continuum for every food; what pillars do you want to stand on?

Rachel Cheatham, RD, founder of nutrition strategy consultancy FoodScape Group, talks food labeling at the IFT show.

Is your product ready for nutrition label changes?

“A 16-ounce drink and a two-ounce bag of potato chips are a single serving. If it’s bigger than that, from 200 to 400%, then you need to declare two columns of information—one for the serving size and one for the whole container.”

Proposed nutrition labels more effective than current labels: survey

Consumers find proposed labels easier to read in less time.

How much do consumers use (and understand) nutrition labels?

New research from the NPD Group is questioning how many US consumers even routinely check nutrition labels anymore.

 FDA’s proposed nutrition label changes emphasize calories, serving sizes

If approved, the new labels would place a bigger emphasis on total calories and update serving sizes, while also drawing attention to added sugars and nutrients such as Vitamin D and potassium.

CRN, NPA submit comments on FDA’s proposed changes to food, supplement labels

Both the Council for Responsible Nutrition and the Natural Products Association have submitted a comments on FDA’s proposed revisions for food and dietary supplement labels.

The FDA’s next step is to deal with the comments and issue final rules.  By when?

Eventually.  Stay tuned.

Jul 29 2014

Last call for comments on proposed food label: more on Added Sugars

August 1 is the deadline for filing comments on FDA’s food label proposals.

Two were released yesterday, one for and one against.

The Union of Concerned Scientists (UCS) organized a statement in support of listing added sugars signed by 280 scientists, physicians, and public health officials (including me).

The press release says:

In a letter submitted as a public comment for the agency’s first label update since 1994, the signatories point out that sugar overconsumption contributes to diabetes, cardiovascular disease and other ailments….Many food and beverage manufacturers add excessive amounts of sugar to their products, including those that they market as healthy options. In our current food environment, many people are unknowingly and unavoidably consuming excess sugar. Given our soaring rates of chronic diseases and the link between sugar and these diseases, citizens have a right to know how much sugar has been added to their foods.

People who signed the letter include many from Healthy Food Action, a national network of health professionals founded by Dr. David Wallinga.  I am a co-author of the statement with UCS staff and Dr. Robert Lustig.

In contrast, the American Society for Nutrition (ASN), an organization of nutrition scientists to which I belong, produced a strong statement against labeling added sugars.

ASN also has concerns that the inclusion of added sugars on the label may divert attention away from total calories and other important contributors to weight gain. The inclusion of added sugars on the label may confuse consumers and create the perception that naturally occurring sugars are somehow more beneficial because they are “natural” and do not have health effects similar to added sugars…There is no supporting evidence that indicates that the inclusion of added sugars on the food label will translate into the American public reducing caloric intake from added or total sugars or total energy intake…it is important to consider potential unintended consequences of  reformulation as well. When sugar is removed from a solid food product…The replacement is often fat and/or starch which could lead to a product with higher calories per serving. ASN encourages FDA to carefully consider potential adverse consequences of this proposed determination, including gaining input from food scientists…An investment in consumer education… is likely to be most productive for consumer understanding relative to added sugars, and would assure that consumers do not experience increased confusion, which they may encounter if added sugars are declared on the Nutrition Facts label.

These comments, which read as though written by sugar trade association groups, were signed by the president of ASN.  Although the statement letter gives no indication of the process by which these comments were developed, I’m told it was prepared by ASN’s public policy committee.

If so, it would help to know whether members of the committee have financial ties to the sugar industry or to food companies that use sugar in their products.

I wonder how much of the ASN membership agrees with this position on Added Sugars.   I certainly don’t.


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