by Marion Nestle
Nov 6 2011

Food Matters: front-of-package labels again

My monthly (first Sunday) Food Matters column in the San Francisco Chronicle appears today.  This time, it’s about the fuss over front-of-package labels.

Q: I’m completely confused by all of the little check marks and squares on food packages telling me they are healthy. Do they mean anything?

A: The Food and Drug Administration feels your pain. It sponsored two studies by the Institute of Medicine to rationalize front-of-package nutrition ranking systems.

The institute released its second report last month; it advises the FDA to allow front-of-package labels to state nothing but calories and nutrients to avoid: saturated and trans fat, sodium and sugar (go to

The institute’s proposal gives products one point for not containing too much of each of these nutrients. It suggests displaying the points like Energy Stars on home appliances with zero to three stars, depending on how well the product meets nutritional criteria.

This is a simple system, instantly understandable. I think it is courageous. The institute’s proposal benefits consumers. It does not help companies sell junk food.

Selling or educating?

No food company wants to display nutrients to avoid. For the food industry, the entire point of front-of-package labels is to market products as healthy or “better for you” no matter what they contain. Front-of-package labels are a tool for selling, not buying. They make highly processed foods look healthier.

Will companies accept a voluntary labeling scheme that makes foods seem worse? Doubtful.

Nutrition ranking symbols began appearing on food packages in the mid-1990s, when the American Heart Association got companies to pay for displaying its HeartCheck.

Food companies then established their own systems for identifying “better-for-you” products. PepsiCo, for example, developed its own nutritional standards and proclaimed hundreds of its snacks and drinks as “Smart Choices Made Easy.”

In an attempt to bring order to this chaos, food companies banded together to develop an industry-wide system. Unfortunately, their joint Smart Choices checkmark appeared first on Froot Loops and other sugary cereals. The ensuing ridicule and legal challenges forced the program to be withdrawn.

At that point, the FDA, backed by Congress and other federal agencies, asked the Institute of Medicine for help.

The institute released its first report last year. It revealed inconsistencies in the 20 existing ranking schemes from private agencies, food companies and supermarket chains. Toasted oat cereal, for example, earned two stars in one system, a score of 84 (on a scale of 100) in another, and a score of 37 in a third.

The report said labels should display only calories and to-be-avoided nutrients. Labels should not display “good-for-you” nutrients – protein, fiber, and certain vitamins and minerals – because these would only confuse consumers and encourage companies to unnecessarily add nutrients to products for marketing purposes.

Although the FDA was waiting for the second institute report before taking action, the food industry wasted no time. The Grocery Manufacturers Association and Food Marketing Institute introduced their own system.

Complicated approach

They got their members to agree to a more complicated system, “Nutrition Keys,” based on nutrients to avoid but also including up to two “good-for-you” nutrients.

Food companies immediately put Nutrition Keys’ symbols – well established to be difficult for consumers to understand – on package labels where you can see them today. Now called Facts Up Front, the symbols are backed by a $50 million “public education” campaign.

The reasons for the industry’s preemptive strike are obvious. The second Institute of Medicine report gives examples of products that qualify for stars – toasted oat cereal, oatmeal, orange juice, peanut butter and canned tomatoes, among them.

It also lists the kinds of products that would not qualify for stars, including animal crackers, breakfast bars, sweetened yogurt and chocolate milk.

So the industry argues that consumers “want simple and easy to use information and should be trusted to make decisions for themselves and their families … rather than have government tell them what they should and should not eat.”

But why, you ask, does any of this matter? I view front-of-package labels as a test of the FDA’s authority to regulate and set limits on any kind of food industry behavior. If the FDA cannot insist that food labels help the public choose healthier foods, it means the public has little recourse against any kind of corporate power.

Perhaps Facts Up Front will arouse the interest of attorneys general – just as the Smart Choices program did.

In the meantime, the industry’s pre-emption of FDA labeling initiatives is evidence that voluntary schemes don’t work. Labeling rules need to be mandatory.

Let’s hope the FDA takes the Institute of Medicine’s advice and starts rule-making right away.

Marion Nestle is the author of “Food Politics” and “What to Eat,” among other books, and is a professor in the nutrition, food studies and public health department at New York University. E-mail comments to

  • On IOM: “This is a simple system, instantly understandable.”

    On F-up-F: “Food companies immediately put Nutrition Keys’ symbols – well established to be difficult for consumers to understand – on package labels where you can see them today.”

    I am no industry shill, and am dispassionate on the subject. I just want evidence. Is the case clear that avg consumer can understand bad ingredients vs bad + “good” ingredients on packaging? Conversely, is is the way industry presents it.


  • Ellen

    It’s baffling that Dr. Nestle considers the front-of-package labels the IOM is calling for “an inherently bad idea” that “make highly processed foods look healthier, whether or not they really are” and STILL supports them, solely because they would show that the FDA is powerful. It really makes it clear that her goal is to increase the power of the federal bureaucracy, even at the expense of public health.

  • Hi, Ellen.

    Sorry, I am confused. I assume the quotes you added to your post were spoken by Dr. Nestle, but I did not find them in this article. The one line I thought you quoted from this article was “make highly processed foods look healthier, whether or not they are”, but the sentence I found was “Front-of-package labels are a tool for selling, not buying. They make highly processed foods look healthier.”

    From what I read, it seems that Dr. Nestle is saying that Front-of-package labels, as they are now and based on the food industry’s influence, make processed foods look healthier, whereas the IOM’s suggested front-of-package labeling would be far more helpful.

    Am I incorrect in this interpretation?

  • Ellen

    Hi, Kevin– the quotes are from her Oct. 20 post on front-of-package labeling (, in which she does say that she considers all front-of-package labeling, including the one the IOM proposes, to be an inherently bad idea, and that whether or not they’ll help people make healthier choices and be healthier is an open question. Her support for the IOM’s scheme in spite of considering it a bad idea without much evidence to show that it will lead to healthier choices speaks volumes about her true priorities.

  • Michael Bulger


    Your quote from the Oct. 20 post leaves out what she wrote next: “Nevertheless, the IOM proposal is a huge improvement over what food companies are now doing.”

    FDA is currently facing a choice: Set rules that adopt IOM’s proposal, or let the industry use its own standards and regulate itself.

    Forced to make such a choice, Dr. Nestle is hoping FDA picks the lesser of the two evils.

  • Ellen

    Michael, the bottom line is that in that post Dr. Nestle said that the reason this issue matters is that it’s “a test of the FDA’s authority to regulate and set limits on any kind of food industry behavior.” Not because it’ll promote healthier choices. Not because it’ll lead to better health outcomes. She’s stated that she doesn’t see any evidence that it’ll do either of those things.

  • Michael Bulger

    She clearly differentiates the two proposals based on the inclusion or absence of “good-for-you” nutrients. She states that the IOM held that the inclusion of these nutrients on FOP labels would confuse consumers. Clearly, confusing the consumer will be detrimental to health outcomes. It will increase the likelihood that an unhealthy product will be consumed due to confusion.

    I want to be polite here, but I’ll convey what is probably apparent to most regular readers. You seem to be focusing more on criticizing Dr. Nestle then discussing the problems/solutions. And I think that is getting in the way of your reading comprehension.

    If you have another opinion about FOP labels, then I’m sure you’re welcome to comment in a civil and polite manner.

  • That is some sly working on the marketers part. There are many people who know just the “nutritional hotwords” and believe it when they see a package says ‘look, this is good for you because it has Vit C!’ and doesn’t realize that is is a false source and none of the other ingredients are good for the body. This is one area I actually DO hope the FDA does something about, at least until we can become a more educated population about whole and traditional foods over processed ones.

  • Ellen

    As this is somewhat off-topic, and I know comments are moderated here, I won’t be upset if this doesn’t show up, since it’s more in the way of a response to Michael than to the post.

    Michael, you’re probably right that I’m letting anger cloud my interpretation in this case. I’ll try to confine my criticisms of Dr. Nestle to things that have their basis in data and science, rather than overtly questioning her motives.

    But, to me, her motives are clearly not to promote health– it was her response to that 2009 school lunch/breakfast program that demonstrated that to me. Given a report that showed the program’s bad effect on participating students, your response was that we should reform the program (“Healthy, Hunger-Free Kids Act?” was your suggestion). I don’t think that’s the most useful response, but I can respect it, and you’ve given the impression that you truly are interested in health outcomes. Dr. Nestle’s response was that the study showed that the program was great, and that we should expand it to cover all kids. That’s a response that demonstrates to me that she does not care about what effect her recommendations have on health, even on the health of low-income kids, and, yes, it makes me angry to think about it. Everything I read from her is colored by that realization.

  • Anthro


    I do not understand why you are so skeptical of Dr. Nestle’s motives? You seem to scour her writings and then cherry pick tiny nuggets that in turn “outrage” you, while ignoring the consistent and large body of work that she has produced which is clearly in the interest of public health. Have you read any of her books?

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  • Ellen

    Anthro, as I said above, I’m going to try to make sure any criticism I make of Dr. Nestle is as objective as possible in the future, so it’s hard to answer your question, which necessarily calls for a somewhat personal answer. I’ve been reading this site more closely than usual over the past week, and commenting more often, but my first exposure to Dr. Nestle was through the Atlantic’s blog, where in 2009 I read the post I reference above, which struck me as glaringly dishonest; again, as I said above, that colors my response to her work. In just the past week or so, she’s mistakenly claimed that representatives of the meat industry had been surveyed and declared profit to be their #2 priority; she’s cited a web poll as convincing evidence for which diets work for the majority of dieters; she’s criticized the potato lobby’s response to an IOM report (to her credit) while failing to mention that the IOM report was influenced by lobbyists from Sunkist and two groups that lobby for the apple industry (not to her credit). You may see those examples from the past 10 days as cherry-picking, but Dr. Nestle is asking us, as citizens and consumers, to trust her judgment, and, by proxy, the judgment of the agencies she unwaveringly supports. It makes sense to me to be pretty scrupulous about whether or not what she’s writing indicates that she’s worthy of that trust.

    It’s probably going to undermine my own credibility, but, no, I haven’t read her books. To the degree they call out the undue influence of agribusiness/food processing companies on governmental policy, I expect I’d find a lot of common ground with her. But having read her blog, I also expect I’d have to spend a lot of time following up on the footnotes to be confident that what she says is accurate.

  • Jon

    “Education” is interesting. How long until Coke and Pepsi educate us to the fact that their sodas are that holy grail of 90s dieting, fat-free?

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