Last September, FDA officially called for public comments regarding how the agency should define the term healthy as it relates to food labeling. FDA has said its goal is to revise its definition of the word healthy to reflect current findings in nutrition science. The official federal definition of healthy has not been updated for more than 20 years.
During the launch call for public comment back in September, Douglas Balentine, PhD, director of the Office of Nutrition and Food Labeling at FDA’s Center for Food Safety and Applied Nutrition, stated in a blog: “As our understanding about nutrition has evolved, we need to make sure the definition for the ‘healthy’ labeling claim stays up to date. For instance, the most recent public health recommendations now focus on type of fat, rather than amount of fat. They focus on added sugars, which consumers will see on the new Nutrition Facts label. And they focus on nutrients that consumers aren’t getting enough of, like vitamin D and potassium. By updating the definition, we hope more companies will use the ‘healthy’ claims as the basis for new product innovation and reformulation, providing consumers with a greater variety of healthy choices in the marketplace.”
Industry associations the American Herbal Products Association (AHPA; Silver Spring, MD) and the Council for Responsible Nutrition (CRN; Washington, DC) recently shared their official public comments to FDA.
CRN’s main concern was that “nutrient contribution criterion” should continue to be used to determine whether or not a food is considered healthy. The association pointed out that the 2015-2020 Dietary Guidelines for Americans (DGAC) indicate that many Americans do not get adequate intake of some essential nutrients. As such, wrote Andrea Wong, PhD, CRN’s vice president, scientific and regulatory affairs, in the association’s comments, “Foods that are good sources of under-consumed nutrients should bear the ‘healthy’ nutrient content claim to help Americans structure diets that conform to current dietary recommendations”—especially such under-consumed nutrients as iron, protein, potassium, dietary fiber, choline, magnesium, calcium, and vitamins A, D, E, and C.
She also stipulated that foods that are fortified to provide these same nutrients should also be eligible for the “healthy” claim. Finally, she advised that FDA’s definition should allow products that are not necessarily low in fat but rich in healthy fats like mono- and polyunsaturated fatty acids to use the “healthy” claim.
AHPA, meanwhile, proposed that criteria other than nutrient content should also be considered for “healthy” claims. AHPA argued that foods considered to be part of a “healthy eating pattern” should also merit the claim in order to encourage Americans’ intake of healthier foods. It also noted that the latest DGA seem to reflect this sentiment, stating that “rather than focusing purely on reduction, ‘emphasis should also be placed on replacement and shifts in food intake and eating patterns.’”
AHPA also noted that, withinin this framework, herbs and spices that can substitute for salt, for instance, should be considered a healthy alternative. “Such healthy options to reduce sodium intake could allow herb and spice blends or prepared foods that substitute herbs and spices for salt to bear a claim such as, ‘a healthy alternative to salt,’” proposed Michael McGuffin, AHPA’s president, and Anthony Young, AHPA’s general counsel, in their joint comments on behalf of the association. “The ability to make such claims might provide encouragement for food producers to reduce the sodium content in their products and would assist companies that market herbs and spices to help consumers learn more about these as salt substitutes.”
The same goes for added sugar, they wrote. “AHPA suggests that another legitimate option to sugar-sweetened beverages would be unsweetened teas, including black and green teas and herbal teas, and believes again that companies that market teas would be motivated to provide healthier options if regulations allowed a ‘healthy’ claim, such as ‘unsweetened tea is part of a healthy diet.’”