Tell the FDA What You Think ‘Healthy’ on Food Labels Should Mean

UPDATE 12/7/22: The FDA has extended the deadline to submit comments on its new proposed definition of “healthy” to Feb. 16. Our original article follows.

Since the FDA invited stakeholders to weigh in on its new proposed definition of “healthy” on food packaging, the agency has received more than 100 public comments from consumers, nutrition experts and food companies whose products would be directly impacted by the update.

The FDA’s current definition of “healthy” is focused on individual nutrients like total fat and certain vitamins and minerals. It’s based on criteria established in 1994. As the FDA notes, a lot has changed since then.

Since that time, the federal dietary guidelines and nutrition science behind them has evolved. Today, we have a greater understanding of dietary patterns and their effects on health, and we recognize that people tend to build their diets around foods, which are made up of a variety of nutrients, rather than just individual nutrients.

Under the FDA’s new proposed definition, a product would need to contain a certain amount of food from at least one of the key food groups (for example, fruits, vegetables or grains) in order to be labeled “healthy.” The proposed rule also sets limits on how much added sugar, saturated fat and sodium a “healthy” product can contain.

The FDA has already identified some winners and losers.

Under the current definition, foods like salmon, avocados and olive oil do not qualify for use of the “healthy” claim but under the proposed definition, they would. Conversely, foods like sweetened cereals and yogurt that currently qualify as “healthy” would no longer be able to bear the claim due to new restrictions on added sugars.

The majority of the comments submitted thus far support the new definition. But that’s not to say everyone’s a fan. And some don’t think the FDA should be telling consumers what is and what isn’t healthy in the first place. (The FDA is also mulling the idea of a “healthy” symbol that food companies can use to label products that meet the new definition.)

Here are some excerpts from the 114 comments, as of this writing, submitted to the FDA. (Note: Some of the excepts have been lightly edited for clarity.)

In support of the proposed definition

• I strongly support this rule. Firstly, putting “healthy” labels on food packages helps everyone, including those with limited nutritional knowledge and language proficiency like my immigrant family, make the right choice of nutritious foods. We just need to look for the “healthy” labels on the products. (Full comment.)
• In 2022, updating the term “healthy” on food labels through the FDA makes sense given the advancements in food science. The definition of “healthy” has not been updated by the FDA in nearly 30 years, indicating that the current understanding of the term is outdated. (Full comment.)
• The average American on the road to being health conscious often doesn’t delve deep into the nutritional label, past the calorie count. … I believe the new definition will be a step in the right direction in helping the nation curb its current obesity epidemic and to reduce the number of people newly diagnosed with chronic illnesses. (Full comment.)
• The updated definition of the term “healthy” in regards to food labeling will be beneficial to individuals who have a desire to make healthier choices, but lack the time or resources to do more than a cursory glance at nutrition labels to make educated purchasing decisions. (Full comment.)
• Healthy is a word that should mean healthy, not somewhat or kind of. This change would initiate a change to the way people consider food. (Full comment.)

In opposition to the proposed definition/any definition 

• Our company, OGO Foods, offers a healthy snack that achieves 100% complete nutrition by complying with the FDA’s Daily Value guidelines for persons 4 years and older. … We already comply with the “healthy” guidelines set out in this proposed rulemaking for saturated fat and salt. Our concern lies with the “added sugar” recommendation. … It is our belief that sugar has been unduly vilified recognizing that our brains run on glucose and require 120 grams of it per day. (Full comment.)
• There is no credible evidence that saturated fats are harmful. Therefore I disagree with the proposed 20 percent limit on saturated fat in oils. (Full comment.)
• My first concern is that seafood is usually above 10% DV for sodium when caught from the ocean. Only two of our several natural seafoods products are below 10% DV. The products do not have anything added to them, they are natural, no additives or preservatives. However, they still test above 10% DV from an accredited lab. This needs to be considered. (Full comment.)
• These overly broad characterizations will inevitably exclude some foods that may be part of a healthy diet. For example, proposed criteria will exclude white bread due to the “3/4 oz whole-grain equivalent” minimum required to meet the “grain” food group requirement. (Full comment.)
• Labeling foods as “healthy” in isolation has little meaning, given that the healthfulness of a diet is defined in large part by the individual person, their lifestyle and (most crucially) the overall mix of foods more so than any individual ingredient or food. Providing such a label simplifies what constitutes “healthy” to the extent that it’s gratuitous. (Full comment.)

If you would like to submit a comment, click here. The deadline is Feb. 16.

Find more of our coverage on “healthy” claims here.