by Marion Nestle
Oct 13 2010

IOM Front-of-Package Label Committee releases Phase 1 report

The Institute of Medicine (IOM) released its first Front-of-Package (FOP) labeling report this morning. Phase I is a tough, detailed examination of about 20 of the existing FOP schemes along with some recommendations about what such schemes ought to do.

FOP labels are those little spots, check marks, and tokens that are all over food packages these days and that are supposed to indicate that the product is especially healthy for you.  They may seem utterly trivial, but they are of desperate importance to food companies.  FOP labels sell food products.  Food marketers love them and need them.  The FDA worries that having so many of them confuses the public, and that the schemes are based on criteria that serve industry purposes more than to promote public health.

As the IOM press release explains:

A multitude of nutrition rating, or guidance, systems have been developed by food manufacturers, government agencies, nutrition groups, and others in recent years with the intent of helping consumers quickly compare products’ nutritional attributes and make healthier choices. Ratings are typically communicated to shoppers through symbols placed prominently on food packaging, usually on the front, or on retail shelf tags. Unlike the Nutrition Facts panel, these rating systems and symbols are unregulated, and different systems focus on different nutrients. The variation may confuse consumers, and questions have been raised about the systems’ underlying nutritional criteria.

The committee did a terrific analysis of current FOP schemes.  My favorite parts are its

  • Clear, concise histories of nutrition and FOP labeling (students: take note!)
  • Detailed evaluation of the strengths (few) and weaknesses (many) of the existing schemes
  • Demonstration of the inconsistent results of applying the schemes to specific foods

The report gives examples of the inconsistent results of three scoring schemes: Guiding Stars, NRFI [Nutrient-Rich Foods Index], and Nu-Val

  • Instant oatmeal received 3 Guiding Stars, and scores of 87 by NRFI and 39 by NuVal.
  • Non-instant oatmeal received 2 Guiding Stars, and scores of 22 by NRFI and 57 by NuVal
  • Toasted oat cereal received 2 Guiding Stars, and scores of 84 by NRFI and 37 by NuVal
  • Fat free milk, 1% fat milk, and fat free plain yogurt received 3 Guiding Stars, but fat free milk was scored 56 by NRFI and 91 by NuVal; 1% fat milk was scored 30 by NRFI and 81 by NuVal, and fat free plain yogurt was scored 43 by NRFI and 96 by NuVal.

The committee’ key recommendation: FOP labels should deal with just four nutrients: calories, saturated fat, trans fat, and sodium.

These nutrients, says the committee, “are routinely overconsumed and associated most strongly with diet-related health problems affecting many Americans, including obesity, heart disease, high blood pressure, Type 2 diabetes, and certain types of cancer.”

Comment: Trans fat seems unnecessary here.  It is already out of most packaged foods.   Or maybe the committee thinks that leaving it off will give food companies permission to put hydrogenated oils back in?

The committee chose not to add sugars to this list:

The committee concurred that both added and naturally occurring sugars contribute to the caloric content of foods and beverages and overconsumption of high-calorie products can lead to obesity.  Highlighting calories per serving in nutrition rating systems would address this concern.

Comment: I think consumers want to know about added sugars in food products.  I certainly do.

Phase II comes next

It will examine designs and look at consumer understanding of the labels, and will discuss “the pros and cons of having a single, standardized front-label food guidance system that is regulated by the Food and Drug Administration.”

Presumably, Phase II will deal with questions that are not addressed in the Phase I report:

  • Will this scheme supersede all of the other labeling systems currently on food packages?
  • Will it be voluntary or mandatory?  For all food products, or just selected ones?
  • If the scheme is voluntary, why would food companies choose to use it since it mostly highlights the negatives—the nutrients to be avoided?
  • How will it affect the nutrient-content claims currently on food packages?  (Examples: “Contains 8 vitamins!”  “100% vitamin C!” “High fiber!”)
  • How will it affect shelf-labeling schemes such as the Nu-Val system used at Price Chopper supermarkets and the ANDI system used by Whole Foods?

FOP labels are about marketing, not health

This scheme, like the many others developed by food companies singly or together, is designed to help the public decide whether one highly processed, packaged food product is nutritionally better than another.

As I have discussed many times on this site, this approach raises a philosophical question: Is a slightly “better for you” food product necessarily a good choice?

I hope the committee will ponder this and some of my other questions as it enters Phase II.

Addendum: I gather from what I’ve heard about the press conference this morning that some of my questions were answered.  The FOP proposal will not affect nutrient content claims on the front of packages.  Companies will still be able to proclaim the nutritional benefits of their products in words and banners.  They just won’t be able to use them in whatever symbol gets chosen.  So what difference will this report make?  Not much, alas, except to get rid of the silly symbols in use right now.

Update, October 14:  William Neuman’s account of this event in the New York Times starts with this: “Tell us how your products are bad for us.”

  • Very interesting and amazing news. I’m a little disappointed that they don’t focus on added sugars but then again, most packaged foods (i.e. not whole foods) can probably be associated with added sugars anyways. Still, it would be nice to have it.

    Also, if they’re focusing on revamping the serving sizes so that they’re more realistic, couldn’t that potentially allow them to hide trans fat even more because of the less than .5g rule?

  • Christine Reese, MS, RD

    I do not believe this will do much to curb our burgeoning waistlines nor health problems. Basically, Pringles can make a fat-free, low sodium chip and it will be considered a health food. If that is not enough, they will probably start fortifying the chips with vitamins and minerals (they have already jumped on the “multigrain” bandwagon).

    I agree with Ms. Nestle that the FOP label mainly serves to help us choose among products only marginally different from each other; however, since we are talking about processed food items, the label can only do so much. Maybe it is time to give Americans some tough love. I feel that placing these labels on processed products gives people the idea that these foods are fine to eat. As a dietitian, I know I need to meet people where they are at, but I do not want to deceive, either. Instead of spending money helping the public choose the best processed item, let us spend it helping them learn to use whole foods.

  • Bobby

    At the office microwave line at lunch I ask coworkers about the FOP symbols and about the nutrient content of their prepackaged meal products. Just about everyone knows that what they are eating isn’t healthy (i.e 1600 mg sodium in a prepackaged lunch soup!) but they don’t feel they have any better alternative in their free-time-deprived lives.

    They definitely buy these products using a decision process based on what I call “label appeal in the supermarket aisle,” which seems to be a 1-5 second decision process, which I assume is highly researched by the food companies. A nice picture, some spurious and deceptive health claims, and it goes into the shopping cart.

    I really like the traffic signal system, red, yellow, green, where the consumer knows RIGHT AWAY what is a quick summary of the actual facts of the food, and not the corporate-approved deceptive health claim designed to distract the consumer more than educate her about the contents of the meal.

    I tried some of these frozen meals in 1993, and never did again, because I have decided to show some respect for what goes into my body. Many busier people seem to think these frozen meals are acceptable substitutes to real food, which is so very sad.

  • MA

    @Bobby – wow! People know, but aren’t willing to actually do anything about it? I agree that it’s sad, and can’t imagine thinking so little (literally) about what I’m eating!

    I really don’t get this whole FOP label idea. I don’t see how the information is any different than what’s on the back. Someone please tell me – what am I missing here?

    Are people truly so disinclined to physically turn a package over and READ what’s already printed there? Perhaps it’s just too much to ask them to take it one step further and do the math involving serving size and how much one actually consumes.

    Maybe we should eliminate all FOP labels (and all other claims) and make people look at the info that’s already provided.

  • Dear Marion (and Dr. Nestle fans)-

    I write, Marion, as always, in the spirit of respect and friendship that binds us. We agree far more than we disagree, but in this space, we have some disagreement.

    First, I agree with one of the others commenting here that a major hazard of simply calling out a short list of ‘bad actors’ creates an enormous loop hole for food companies and their marketing: fat-free, low-sodium junk food.

    As for the remarks about systems (NuVal, Guiding Stars, NRFI) disagreeing, two comments:

    1) these systems could differ considerably, yet all be directionally correct and useful. For example, MapQuest directions might differ from the GPS in your car, and both might differ from the route you would map out yourself- yet all might get you to your destination. You seem to be suggesting that as soon as we saw disagreement between MapQuest and GPS, we abandon both.

    More directly related to what I do as a physician, we can measure cardiac risk with CT imaging of coronary calcification; stress-testing; nuclear medicine scans; or coronary angiography, to name a few. These do not agree with one another perfectly by any means, but all point fairly reliably in the same direction. We strive to find the ‘best’ measure (we do endothelial function research in my lab, to that end), but we don’t abandon useful measures in the interim.

    2) that notwithstanding, there is an even more important consideration when viewing several systems that disagree: maybe one is good/right, and the others are not. There is the ‘throwing out the baby with the bathwater’ hazard, in other words, if discrepancies mean: abandon all.

    As I’ve conveyed to you before, the NuVal scores have been tested against actual health outcomes- all-cause mortality, cardiovascular events, diabetes, etc.- in over 100,000 people in an independent study at Harvard. The data were presented at Experimental Biology this year, and the paper is now in press. To my knowledge, no other system- nothing currently on nutrition packages- and certainly not the proposed approach by IOM- has been tested against this standard. Some other systems have been, and have failed- such as the system developed for the Food Standards Agency in the UK.

    If the reason we care about nutrition is because we care about health (is there another reason?) then shouldn’t the association between how we provide nutrition guidance and health outcomes be an important consideration in separating better from lesser systems?

    I, too, support the IOM’s apparent intention to curtail the prevailing food industry practice of accentuating the positive, however trivial, and obscuring the negative. But I don’t think their proposal addresses this comprehensively. I offer more fully developed thoughts on the deficiencies of highlighting only some of the bad and the ugly, and none of the good, here:

    With warmest regards,

    David L. Katz, MD, MPH, FACPM, FACP
    Director, Prevention Research Center
    Yale University School of Medicine

    Principal Inventor, Overall Nutritional Quality Index (ONQI)
    used in the NuVal system

  • Cathy Richards

    Not surprised to see Dr. Katz’s defense of NuVal.

    As much as I admire so much of what Dr. Katz does, and as interesting that NuVal is, I am not a cheerleader for the system for the following reasons:

    1. It requires extensive nutrition analysis, including many micronutrients. This extensive analysis is not accessible to many start-up and smaller food producers, giving an unfair edge to the corporate food and processed food systems. The comprehensiveness of NuVal is one of its major plusses and major detriments. Simpler systems typically use nutrients visible on the package, and that also favours processed food, but at least basic nutrient analysis can be done for free from USDA/Health Canada tables, rather than needing a laboratory analysis.

    2. The NuVal system uses an algorithm to calculate a score. This is not a transparent system, nor is it a freely accessed system. For example, I cannot develop a product privately and then test its NuVal score to see if there’s something I should tweak about my product to get a better score.

    3. I believe the NuVal system uses the same algorithm for all food groupings, and although it tries to overcome the disparity between food groups, it doesn’t always occur.

    4. If a company chooses not to participate in the NuVal system, the consumer will not know the score of the product, and will not be able to estimate a NuVal score using information on the package. A product beside it on the shelf with a NuVal score may have that ‘advertising’ edge over a non-scored item.

    NuVal is a great start, and took the conversation of scoring nation wide. But these access/transparency issues need to be explored further.

  • Good afternoon to all,

    I would just like to respond to Cathy Richard’s comments as they present some inaccuracies about the NuVal System. First and foremost, food manufacturers do not choose to have their products scored nor do they pay to have their products scored. NuVal LLC goes through the laborious process of scanning nutrition and ingredient information on products UPC code by UPC code to put them through the imputation and scoring process. No laboratory analysis is involved. We have a process by which we score national and regional brands, and private label brands in our retail partners as our intention is to provide the NuVal score on all products, providing consumers with the information they need to make the most nutritious choices possible. It sounds like, Cathy, that you work with a food manufacturer, and to that end, I will mention that we offer a series of webinars for manufacturers to provide an in-depth review of the scoring process as well as provide guidance on how products can be reformulated to have better overall nutrition. If you’d like more information on this, please feel free to email me at

    Annette Maggi, MS, RD, LD, FADA
    Sr. Director of Nutrition
    NuVal LLC

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  • Cathy Richards

    Sorry for my inaccuracies. And no, trust me, I do not work for a food manufacturer. That’s actually really funny, my colleagues in public health would be laughing so hard at that they would be snorting!
    I didn’t mean to imply that a company had to pay to do NuVal. But my understanding is that a number of nutrients that do not appear on a nutrition label need to be known for the NuVal score. I didn’t realize a UPC label could replace a lab analysis.
    Nonetheless, I know about a lot of healthy foods that do not have UPC labels.
    I guess I’m too naive about the system to be making comments on it. I had seen a presentation by Dr. Katz, and chatted with him afterwards about it, but guess I didn’t have enough info, or enough memory, to make my comments.

  • CK


    I am interested in your thoughts regarding the four nutrients and the information you quoted below :

    These nutrients, says the committee, “are routinely overconsumed and associated most strongly with diet-related health problems affecting many Americans, including obesity, heart disease, high blood pressure, Type 2 diabetes, and certain types of cancer.”

    Specifically, do you agree that fats are more strongly associated with Type 2 diabetes than sugars?

    And, are calories “nutrients”?


  • Marion

    @CK: Obesity is a risk factor for type 2 diabetes, and obesity is the result of excessive calories from any source. Nutrients include sources of energy. Energy is measured in calories. That’s my interpretation. Hope it helps.

  • Jon

    I would add refined carbohydrates to the list of overconsumed nutrients. I mean, the sugar Americans consume alone…And sugar is easily the most addictive calorie source.

    Of course, people do things on a nutrient-by-nutrient analysis, rather than looking at the whole.

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  • hakikat

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