Currently browsing posts about: Labels

With all the fuss over defining the term ultra-processed, public and private groups are filling the gap with labels that identify foods that are not ultra-processed.

I know of three ultra-processed labeling initiatives so far.

I.  Leading the way is the Non GMO Project. It already is licensing foods meeting its non ultra-processed standards to carry this seal.

II.  California is considering a front-of-package label to indicate foods that are not ultra-processed; it expects only about one-third of processed supermarket foods to meet its criteria.

III.  And in Europe, Nutri-Score (as I written about previously) is considering adding something about ultra-processing to its current labels.  Even food products meeting its A criteria can be ultra-processed.

Comment: While fusses about the definition of ultra-processed continue, labels like these ought to help people recognize and cut down on such foods.  As for me, I’m not too worried about the definition.  As one of my colleagues put it, as with pornography. everyone recognizes an ultra-processed food when they see one.

Addition

Thanks to Jim Krieger for sending two more.

• NonUPF Certified

• WISEcode Non-UPF Verified

And a reader from Norway sends this one (and more information about it)

While we are on the topic of labels, here’s the USDA’s newest:

“Tastes like freedom?”  You have to love the Orwellian rhetoric.

“Our great patriot ranchers and producers grow, raise, and harvest the world’s safest, most affordable, and abundant food supply. American consumers want to support America by buying American and this label will strengthen our food supply chain through transparency, fairness, and trust,” said USDA Secretary Rollins. “This new standard policy ensures producers who invest in a fully American supply chain can compete fairly, and it gives consumers the confidence they deserve about the food they bring home.”

Here’s what this is about:

Under this standard, the “Product of USA” label is reserved exclusively for meat, poultry, and egg products from animals that were born, raised, harvested, and processed in the United States. The claim is voluntary, but companies using it must meet this transparent and verifiable requirement.

It is part of the USDA Plan to Fortify the American Beef Industry.  This “focuses on rebuilding domestic capacity, improving transparency across the supply chain, and ensuring U.S. ranchers can compete on a level playing field.”

And, you can “Learn more at productofusa.gov,”

RFK Jr has promised that we will soon ahve a new front-of-package label..  As soon as they define ultra-processed foods,

Every food in your grocery store will have a label on it,” Kennedy told [Joe] Rogan. “It’ll have, maybe, a green light, a red light, or a yellow light telling you whether or not it’s going to be good for you.”

This has been in the works for a long time, as I’ve written previously.  The FDA’s original version did not have colors so we don’t know yet what this might look like.

But which of the many possible designs is likely to be most effective?  We now have the answer to that question: Efficacy of front-of-package nutrient labels designed for mandatory implementation in the USA: an online randomised controlled trial.

The study asked particicpants to identify products with the most and least healthful nutrition profiles from among these designs.

The clear winner: The last column (“multi-high-in-label), which greatly outperformed the ones like what the FDA is proposing.

The winning label helped participants

• Identify healthy products
• Avoid interpreting unhealthy foods as healthy
• Recall label contents

The obvious interpretation: Use the winners.

These, by the way, are much like those used in Chile, Mexico, and other Latin American countries, with much evidence for effectiveness.

Resources

• Open-access Article: https://www.thelancet.com/journals/lancet/article/PIIS2468-2667(26)00027-7/fulltext 
• Link to article and Appendix
• Press release: https://www.ucdavis.edu/news/new-research-suggests-fda-should-consider-redesign-proposed-nutrition-labels
• Lancet PH Podcast: https://www.buzzsprout.com/1793453/episode_players/18876284

A reader, Doug Williams, alerted me to Canada’s new food warning label.  Even better, he followed it up with a photo.

Here’s what the warning label looks like up close.

Canada based the label on extensive consultation.

For most foods, the warning label is required when sugar, saturated fat, or sodium reach 15% of the Daily Value.  For saturated fat, for example:

There are lots of exceptions.  But the warning label is easy to spot.

The FDA is supposedly working on a warning label.  I can’t wait to see what the MAHA FDA comes up with.

Canada’s is better.  The ones in Latin America are better yet.  Let’s hope.

Resources

• Healthy Eating Strategy
• Front-of-package nutrition labelling backgrounder
• Front-of-package nutrition symbol labelling guide for industry
• Front-of-package labelling consumer research and consultation
• Summary of amendments published in the Canada Gazette, Part II: Nutrition symbols, other labelling provisions, vitamin D and hydrogenated fats or oils
• Regulations Amending the Food and Drug Regulations (Nutrition Symbols, Other Labelling Provisions, Vitamin D and Hydrogenated Fats or Oils)
• Marketing Authorization to Permit a Lower Calcium Threshold for Exemptions from the Requirement for Prepackaged Products to Carry a Nutrition Symbol in the Case of Cheese, Yogurt, Kefir and Buttermilk
• Interim policy statements on certain front-of-package nutrition labelling requirements

The FDA announced that it is revoking 52 obsolete standards of identity for food products.  It said it is doing this as part of the Trump Administration’s deregulatory agenda.

“I’m eliminating outdated food regulations that no longer serve the interests of American families,” said HHS Secretary Robert F. Kennedy Jr. “Today marks a crucial step in my drive to cut through bureaucratic red tape, increase transparency and remove regulations that have outlived their purpose.”

Two readers, Sharon Sass and Ashley Schuering, wrote to ask me to comment on this move.

For starters, the purpose of the Standards of Identity for Food (SOI) is to ensure that a product contains what is expected.  The SOI states what a food must contain, what is optional, and, sometimes. the amount or proportion of ingredient, and the method of production or formulation.

Current SOIs are at 21 C.F.R. Chapter 1, Subchapter B, Parts 131-169.

The easiest example is infant formula.  The SOI states the amounts of each nutrient that must or can be in the formula.  Infants depend entirely on those nutrients.  The SOI makes sense.  The FDA is not touching it at the moment.

It is more difficult to make sense of the SOI for fruit preserves and jams.  One of the rules reads like this:

Any combination of apple and one, two, three, or four of such fruits in which the weight of each is not less than one-fifth and the weight of apple is not more than one-half of the weight of the combination; except that the weight of pineapple may be not less than one-tenth of the weight of the combination.

The SOI also specifies the use of these ingredients:

(1) Nutritive carbohydrate sweeteners.

(2) Spice.

(3) Acidifying agents.

(4) Pectin, in a quantity which reasonably compensates for deficiency, if any, of the natural pectin content of the fruit ingredient.

(5) Buffering agents.

(6) Preservatives.

(7) Antifoaming agents, except those derived from animal fat.

This, it seems to me, could use some updating.

A law firm, Morrison Foerster, has a succinct summary of the relevant regulatory history.

FDA recognized the need to modernize its SOIs dating back to 1995. In 2005, FDA and the U.S. Department of Agriculture (USDA) published a proposed rule in an effort to initiate the process of modernizing SOIs. Then, in 2018, as part of the agency’s Nutrition Innovation Strategy, FDA sought to restart its efforts to modernize its aging SOIs. At a public meeting the following year, stakeholders expressed broad support for FDA’s and USDA’s efforts to finalize the 2005 proposed rule and called for a reopening of the comment period for the 2005 proposed rule to collect information on manufacturing, food technology, market trends, and nutrition science. FDA and USDA ultimately reopened the comment period in 2020. Based on the comments received, the agencies withdrew the 2005 proposed rule to “reconsider how best to approach general principles and food standards modernization

Here is the List of Standards Affected by FDA’s First Set of Food Standard Revocation Rulemakings

Comment

I don’t think this makes any difference.  The revocations will give food companies more flexibility in what they put into the listed products, but they will have to disclose the contents of their products on the food label.  Even if they remove real ingredients and substitute additives, they will have to say what is in the products.  The moral: read food labels!

The FDA’s Actions

• A direct final rule revoking standards for 11 types of canned fruits and vegetables that are no longer sold in U.S. grocery stores, including seven standards for fruits artificially sweetened with saccharin or sodium saccharin (and a companion proposed rule in case it needs to adjust this).
• A proposed rule to revoke standards for 18 types of dairy products.
• A proposed rule to revoke standards for 23 types of food products.

__________

Forthcoming November 11, 2025: What To Eat Now

I first read about this in a Forbes article: New Study: Front-Of-Pack Warning Labels Don’t Lower Obesity Rates.

As the FDA mulls interpretive food warning labels, a Georgetown University study shows these schemes have been powerless to halt obesity trends.  In an attempt to tackle stubbornly high adult obesity rates over 40% in the US, the FDA is advancing a proposed front-of-pack (FOP) label that highlights whether a food or beverage contains low, medium or high levels of sugar, saturated fats and sodium. But a new study from Georgetown University titled Can Front-of-Pack Product Labeling Fix the Obesity Crisis says that the FDA has not learned the lessons from other countries using such interpretive food warning labels: there is no hard evidence that they have been effective in improving consumer diets or in arresting rising obesity rates.

The author of this article is Hank Cardello, executive-in-residence at Georgetown McDonough’s Business for Impact.

If you click on the link to the study, you discover than Cardullo himself is its author.

Hank Cardello, executive-in-residence at Georgetown McDonough’s Business for Impact, has published a white paper titled,“Can Front-of-Pack Product Labeling Fix the Obesity Crisis?” This paper argues that front-of-pack (FOP) food labeling has not led to meaningful improvements in public health outcomes. It evaluates data from multiple countries to test the efficacy of other FOP labeling initiatives.

Both the article and his White Papert disclose the funder: the Consumer Brands Association, formerly known as the Grocery Manufacturers of America, which represents Big Food.

Comment

I can understand why the food industry does not like warning labels or any other front-of-pack label that might reduce product sales, which studies of Latin American warning labels show they do.  So this piece is predictable.

If you want people to lose weight, they have to eat less.  Eating less is very bad for business.

What good are front-of-pack labels?  At best they alert consumers to avoid high-calorie foods formulated to get us all to eat more of them.

But that’s just a start.  To lose weight, you also have to make sure the rest of your diet does not replace the calories you just saved.

Cardullo’s suggestion is smalled portions.  Good idea.

In the meantime, warning labels could help and I hope the FDA comes up with good ones.

________________

Published tomorrow!  Information is here.

The FDA is an agency within the Department of Health and Human Services, now headed by Robert F. Kennedy, Jr.  It is getting busy on carrying out Secretary Kennedy’s stated agenda.  It took four actions of interest last week.  Check out #3; it requires action.

I.  Approved Three Food Colors from Natural Sources

Since the HHS and FDA announcement last month during a press conference at HHS on petroleum-based food dyes, more U.S. food manufacturers have committed to removing them within the FDA’s set time frame of the end of next year.

“On April 22, I said the FDA would soon approve several new color additives and would accelerate our review of others. I’m pleased to report that promises made, have been promises kept,” said FDA Commissioner Martin A. Makary, M.D., M.P.H. “FDA staff have been moving quickly to expedite the publication of these decisions, underscoring our serious intent to transition away from petroleum-based dyes in the food supply and provide new colors from natural sources.”

FDA approved color additive petitions for:

• Galdieria extract blue, a blue color derived from the unicellular red algae Galdieria sulphuraria (by petition from Fermentalg).
• Butterfly pea flower extract, a blue color that can be used to achieve a range of shades including bright blues, intense purple, and natural greens (Sensient Colors LLC)
• Calcium phosphate, a white color approved for use in ready-to-eat chicken products, white candy melts, doughnut sugar, and sugar for coated candies (Innophos Inc).

II.  Announced top priorities for the Human Foods Program

FoodNavigator-USA report that Mark Hartman, who directs the new Office of Food Chemical Safety, Dietary Supplements, and Innovation, says the FDA soon will:

• Reveal how it will deal with the safety of chemicals in the food supply
• Create a new Office of Post Market Review to conduct risk reviews of chemical additives
• Increase transparency and stakeholder engagement in the review process
• Work through 70,000 comments on the FDA’s proposal for reviewing the safety of chemical additives
• Partner with the NIH to research how food additives affect children’s health
• Work with the food industry to phase out synthetic color additives
• Work through comments on sodium guidance
• Think about ways of addressing added sugars
• Identify ultra-processed foods as an “area of emerging study”

III.  Extended the comment period for front-of-package labeling until July 15

We are taking this action in response to requests to extend the comment period to allow interested parties additional time to submit comments. Comments should be submitted to Regulations.gov and identified with the docket number FDA-2024-N-2910.

Recall: This is what the Biden FDA proposed.  Here’s what I said about it (basically, we need something better).

Here’s a real opportunity.  If you want a front-of-package warning label like those in Latin America, here’s your chance to weigh in.

RFK Jr says he wants to Make America Healthy Again.  One way to do that is to discourage sales of food products high in saturated fat, sodium, and added sugars, but also discourage sales of ultra-processed foods.  Identifying foods as ultra-processed, on the basis of their chemical additives as well as their fat, sugar, and salt, would be an excellent step forward.

If you like the warning labels used in Latin American countries, send a note to the FDA Docket.  You have until July 15 to do that.

IV.  Announced a joint research initiative with NIH to address, among other unspecified questions,

• How and why can ultra-processed foods harm people’s health?
• How might certain food additives affect metabolic health and possibly contribute to chronic disease?
• What is the role of maternal and infant dietary exposures on health outcomes across the lifespan, including autoimmune diseases?

Comment

OK.  This represents action or proposed action.  My question: What will the FDA actually do?  I’m particularly interested in the joint NIH research initiative on ultra-processed foods.  Will NIH reverse its stance on Kevin Hall, whose research aimed to answer precisely that question?  I will be watching all this with much curiosity.

The USDA announces updated guidelines for substantiating claims on meat and poultry labels in these categories.

• Animal Welfare Claims
• Breed Claims
• Diet Claims
• Living or Raising Conditions Claims
• Negative Antibiotic Use Claims
• Negative Hormone Use Claims
• Source and Traceability Claims
• Organic Claims
• Environment-Related Claims

It says:

Animal-raising claims, such as “Raised Without Antibiotics,” “Grass-Fed” and Free-Range,” and environment-related claims, such as “Raised using Regenerative Agriculture Practices” and “Climate-Friendly,” are voluntary marketing claims that highlight certain aspects of how the source animals for meat and poultry products are raised or how the producer maintains or improves the land or otherwise implements environmentally sustainable practices…FSIS [USDA’s Food Safety and Inspection Service] last updated its guideline on these claims in 2019.

USDA’s new guidance says it “strongly encourages”

• The use of third-party certification to substantiate animal-raising or environment-related claims
• Substantiating “no antibiotics” claims by testing for antibiotics or using a third-party certifier who does the testing
• Providing data on soil or air quality studies to substantiate environmental claims

Comment

This guidance is voluntary.

This raises immediate questions about the antibiotic claim.  A study conducted by researchers and policy experts at George Washington University found 20% of cattle marketed as “raised without antibiotics” to have been treated with antibiotics.

You would think that fixing this situation requires mandatory regulation, not voluntary.

Groups concerned about animal welfare also object.  The Animal Welfare Institute wants stronger standards.

The ASPCA issued a press release: “ASPCA Condemns Long-Awaited USDA Guidelines that Fail to Meaningfully Improve Oversight of Animal Welfare Label Claims”

ASPCA’s labeling guide points out that claims for cage-free, humane-raised, and pasture-fed, for example,

which often appear on the packaging of meat, egg and dairy products, may indicate better animal welfare but lack strong standards and have no on-farm verification processes, meaning farm conditions and the treatment of animals vary widely across producers.

Voluntary means that producers can voluntarily ignore such guidelines.  Plenty of evidence suggests that many do.

We need a better system.

• The full guidelines.
• The advance Federal Register notice.