The FDA Wants YOU! Help Improve Nutrition Labeling

Help the FDA Improve


The FDA is reconsidering the Nutrition Facts Panel. Almost 20 years after the Nutrition Labeling and Education Act of 1990, and with soaring rates of obesity, one could argue that the goals of a healthier, slimmer America have not been achieved.

The Food and Drug Administration, charged with most foods’ nutrition labeling realizes this. So it has decided to experiment with changes, additions, and omissions in order to improve consumer understanding of what they are about to eat.

But before building the experiment, the FDA is soliciting comments from the public, and that includes us – you, me, and whoever cares about nutrition. Unfortunately, the digital hallways of the federal government are not user friendly and it is not trivial to find the right webpage to comment. This means that in many cases, the only comments come from food manufacturers and trade groups. You can probably guess what their comments will look like.

So here’s some help from Fooducate. Not only did we dig up the single click that takes you straight to the comment page, we’ve also collated Seven Label Improvement Suggestions [see below] that you can suggest to the FDA.

The invitation to comment by the FDA can be downloaded [PDF] or viewed online.

You need to submit your comments by January 19, 2010. For reference, the docket number is FDA–2009–N–0532 and you can submit your comment here.

Seven Suggested Label Improvements:

If you are contemplating what improvements the FDA should undertake, let us help with a few examples. Feel free to “copy paste” when you file your comment with the FDA.

1. Show REAL serving size. Have you ever noticed the ridiculously small serving sizes on packages – 3 Oreos? 15 potato chips? Or a single serve 20 fl oz bottle of cola written up as containing 2.5 servings? Manufacturers like to minimize the servings to toddler size portions so that the nutrition facts per serving won’t seem too bad (calories, sugar, etc…). This is misleading and needs to change to reflect how people really consume food and drink.

2. How much ADDED sugar? The nutrition label states the amount of total sugar in a serving, but it does not indicate whether the sugar is added to the food, occurs naturally, or both. Caloric-ly, there is no difference between added sugar and sugar found naturally in fruits and vegetables. But the benefit of fruits containing naturally occurring sugars is in the additional vitamins, minerals, fiber, antioxidantss and phytochemicals they provide. Added sugars provide no health benefits. They are truly empty calories. People should choose products with as little added sugar as possible. Unfortunately, today consumers can only guess how much sugar has been added to a product.

3. Daily Values for Protein, Sugar. These numbers don’t appear on nutrition labels today and consumers can only guess if 5 grams of protein are a lot or a little. As most people consume plenty of protein daily, this will decrease the marketing hype around high protein bars and snacks. As for sugar, people don’t know what amount is an acceptable daily intake of total sugar, and of added sugar.

4. Zero should be zero. Did you know that if a product contains trans fat, but less than 0.5 grams per serving, it can legally be labeled as 0 gram of trans fat? This is ridiculous. Knowing this, manufacturers can “calibrate” serving sizes to be just under half a gram’s worth of trans-fat, thus earning the right to place the coveted zero number on the nutrition label. But when wolfing down a snack bag (real serving size much larger than labeled – see #1 above), you could be getting even 1.25 grams of trans-fat, all while thinking that the product contains none at all.

5. Caffeine content. Products that contain caffeine should clearly state the amount. People are often surprised to discover caffeine in soft drinks, cakes, and other snack items. Some energy drinks contain ridiculously high amounts. Physicians have asked the FDA to require caffeine labeling on energy drinks.

6. Allow rBGH-free labels. rBGH / rBST is a hormone injected into cows to increase their milk output. The hormone has been associated with various health risks for humans consuming the milk. People should know if their milk comes from cows treated with these hormones.

7. Label Booz. Alcoholic beverages should be labeled as well. At a bare minimum, provide serving size and calories.

Click HERE to submit your comments to the FDA.

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  • Banded Girl

    You give permission to copy and paste the list when submitting comments to the FDA. Does that permission extend to copying and pasting to my blog article on the subject (with credit)? The list and explanations are awesome and I would like to share it with more people.

    • Editorial Staff

      Feel free to spread the gospel, using proper attribution and a link back to this post.

  • uRDietitian

    Great article to get people involved and thanks for the links to submit our comments. However, I am disappointed with your suggestions for the food label changes.
    A serving size should be three cookies and the list of ingredients lets you know what types and how much sugar is added. The labels should not accommodate an individuals poor eating habits.
    Please focus your comments on more important issues like; GMO food labeling, not allowing the adulteration of Organic labeling(check out the article below), banning deceptive marketing and labeling of products, such as the “added fiber” claims and added vitamins that aren’t bio-available, and caffeine content, etc. We need Truth in labeling!

  • FoodFitnessFreshair

    I read an article about this earlier and I really hope the new food label idea gets passed. All those hidden sugar ingredients should be brought to consumers awareness.

  • Carol H.

    Thanks for the handy link… they often do make it difficult to find.

    Unfortunately, this comment period is simply for feedback on how to create/conduct an online survey (next year?) on a select group of 3600 people:
    “FDA is proposing to conduct an experimental study to quantitatively
    assess consumer reactions to potential options for modifying the
    Nutrition Facts label format. The purpose of the study is to help
    enhance FDA’s understanding of consumer comprehension and acceptance of
    modifications to the Nutrition Facts label format.”

    Any comments not addressing how to design/conduct the survey will probably be tossed, but comments that pose suggested questions (e.g., “Ask survey takers how often they notice/read the serving size info,” or “Show people products with the serving size in bold, and see if they notice it more”) are useful for this particular comment request.

    PS: A serving size of 3 cookies would not work because cookies come in many different sizes. That’s why the current standard is one ounce for a serving — it prevents unequal comparisons between products in a category. For small cookies, it could be 3 cookies per ounce/serving, and for larger ones it could be one cookie. Comparisons by weight allow true comparison of calories, etc.

  • E

    I clicked the link to comment and there was no page! I really want to add my 2 cents worth! Can you find the link again?