By the time you read this, FDA may already have issued a proposed rule to change the meaning of Daily Values (DVs) on dietary supplement and food product labels. The proposed rule would impact the food and dietary supplement industry, and if it plays out the way the Council for Responsible Nutrition (CRN) is concerned, it may also have major implications for consumers—implications they may not even be aware of.
For as long as FDA has required DVs on nutrition labels, DVs have been based on the highest Recommended Dietary Allowance (RDA), the average daily dietary intake of a nutrient that is sufficient to meet the requirements of nearly all (97 to 98%) healthy persons. FDA calls this the “population coverage” approach.
However, in the early 2000s, the Institute of Medicine (IOM) completed a massive revision of the entire Dietary Reference Intake (DRI) process. FDA requested that the IOM make recommendations for using the newly developed values for nutrition labeling and, in 2004, the IOM labeling committee recommended that the DVs instead be based on the Estimated Average Requirement (EAR), the amount of a nutrient that is estimated to meet the requirements of about half of all healthy individuals in the population.
Here’s the problem: If these changes were made, 100% of the new DV would cover the basic requirements for about only half of the population, instead of representing the recommended intake for virtually the whole population.
If FDA follows the advice of the IOM committee in its proposed rule, many of the DVs for nutrients would thus be lowered—some, dramatically. The new values would focus on preventing nutrient deficiencies rather than focusing on nutrient optimization.
Consider this: Since FDA allows foods with 10% of the DV to be called a “good source” of a nutrient, a less nutritious food would suddenly be able to make a label claim that it is a “good source” of vitamin C.
Some in the industry might like this approach because it would allow certain foods and dietary supplements to have lower amounts of nutrients yet still claim to provide 100% of the DV. But this approach wouldn’t be ideal for consumers looking to achieve optimal health. CRN believes it would be misleading to redefine the DV to represent anything less than the recommended nutrient intake for the vast majority of the population.
We already know that many Americans are falling short of a number of the nutrients they need, including, but certainly not limited to, several B vitamins, vitamin C, and calcium. The IOM committee’s recommendation would move the goal posts, making you think you have scored a touchdown when you are actually still 10 or 20 yards short.
For example, let’s say the doctor told you to get more folic acid (a B vitamin) in your diet. You might look to a food such as a fortified breakfast cereal or a multivitamin to help accomplish that goal. But under this new rule, the label on your cereal might tell you the product contained 30% of your DV for folic acid, or the multivitamin might tell you the product provided 100% of the DV for folic acid—when actually you would be getting less than the recommended intake because the amount of folic acid needed to qualify as 30% or 100% would have changed.
The DVs used in nutritional labeling certainly need to be updated to reflect the current science, but DVs should still represent the goal of optimal nutrition—and not a mathematical median that only meets the nutrient recommendations for half of the population. FDA should update the data, not the methodology.
One thing is for sure—this is likely to be a highly debated issue. When FDA issued its Advance Notice of Proposed Rulemaking on this topic in 2007, the agency received almost 800 comments, including those from CRN. Stay tuned to learn more from CRN about this issue as it unfolds.
What Do All Those Acronyms Mean?
Daily Value (DV): Daily Values are average levels of nutrients for a person eating 2,000 calories per day. A food item with a 5% DV of fat provides 5% of the total fat that a person consuming 2,000 calories per day should eat. These values are provided on nutrition labels.
Dietary Reference Intake (DRI): Developed by the Institute of Medicine, Dietary Reference Intake is actually a general term for a set of four reference values used for planning and assessing nutrient intake for healthy people: 1) Recommended Dietary Allowance (RDA, see below), 2) Adequate Intake (AI), only used when an RDA for a nutrient cannot be determined, 3) Tolerable Upper Intake Level (UL), the highest daily intake of a nutrient that is likely to pose no risks of toxicity for almost all individuals, and 4) Estimated Average Requirement (EAR, see below).
Recommended Dietary Allowance (RDA): The average daily dietary intake of a nutrient that is sufficient to meet the requirements of nearly all (97 to 98%) healthy persons.
Estimated Average Requirement (EAR): The amount of a nutrient that is estimated to meet the requirements of about half of all healthy individuals in the population.