STRATEGIC PERSPECTIVES: Redefining ‘healthy’ in food labeling: Key themes emerge By The FDA is presently engaged in a public process to redefine the term “healthy” in the labeling of human food products. This Strategic Prospective discusses the FDA’s current position regarding the use of the term “healthy,” its interim guidance announcing its intention to exercise enforcement discretion with respect to some of the criteria for bearing the implied nutrient content claim “healthy,” its motivation for considering a definitional change to “healthy,” and some perspectives and recommendations provided by members of the food industry at a public meeting on the matter. This examination will help determine: (1) the extent to which consumers understand the term “healthy;” (2) whether the new definition of “healthy” should focus on quantitative levels of nutrients (the current definition approach), on food groups and components, or a hybrid of these two approaches; (3) what can be done to make labels less confusing; (4) what factors drive food purchasing decisions; and (5) how consumers can be educated on the meaning of the term “healthy.” FDA’s Current Definition of “Healthy” The FDA regulations in (d) currently provide the regulatory definition for use of the term “healthy” or related terms (such as “health,” “healthful,” “healthfully,” “healthfulness,” “healthier,” “healthiest,” “healthily,” and “healthiness”) as an implied nutrient content claim on the label or in labeling of a food to suggest that a food, because of it nutrient content, may be useful in creating a diet that is consistent with dietary recommendations. The definition establishes the following nutrient conditions for bearing a “healthy” claim: (1) specific criteria for nutrients to limit in the diet, such as total fat, saturated fat, cholesterol, and sodium; and (2) requirements for nutrients to encourage in the diet, including vitamin A, vitamin C, calcium, iron, protein, and fiber [emphasis added]. The criteria are linked to elements in the Nutrition Facts label and
“Healthy” as a broad term. Participants stressed that devising a universal, definition could prove challenging because one’s perception of what “healthy” means is subjective. Some key points included: Foods are healthy only within the context of a healthy dietary pattern and overconsumption of any food regardless of the food components or nutrients can be unhealthy. An individual’s understanding of which foods are healthy may depend on his or her health goals. For example, someone trying to lose weight may think of healthy differently than someone wanting to build muscle. Consumers’ perceptions of what “healthy” means can be influenced by their background, values, culture, family, education, generation, and other personal factors. Consumers can sometimes merge “healthy” with other product claims such as “organic,” “non-GMO,” and “gluten free.” Some people perceive foods with these attributes as healthy, though this assertion is not based on nutritional make-up of the food. While some participants suggested that the term “healthy” should not be allowed in food labeling, others predicted that if “healthy” were not allowed and defined, food producers would likely gravitate more toward terms with a similar meaning such as “fit” and “smart” and potentially increase consumer confusion. Combined definition. Some of the rationale for considering a combined nutrient-based and food component-based definition included: Incorporating more food component criteria into the definition may align better with the Dietary Guidelines for Americans, and allow for the term “healthy” to apply to foods such as avocados and nuts, which do not qualify as “healthy” under the current definition. There should continue to be nutrient-based disqualifying criteria. For example, foods with added sodium or sugar can be part of a healthy diet, although the individual item may not be considered healthy. It is important that nutrients, and the percentage of the DV of those nutrients, continue to be considered in the overall definition of “healthy.” Fortification (adding nutrients) should not be allowed when its sole purpose is to qualify the food for the “healthy” designation.