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Research Roundup

Consideration of nutrition and sustainability in public definitions of “healthy” food: An analysis of submissions to the U.S. Food and Drug Administration

24 April 2024

Dietary guidelines have the potential to align health and food system sustainability goals. The US Dietary Guidelines Advisory Committee (DGAC), an expert scientific panel, recommended for the first time in 2015, that food system sustainability be incorporated into the Dietary Guidelines for Americans (DGA).

This study (1) aimed to better understand how the public defines “healthy” foods and to determine whether the public considers sustainability in the context of healthy eating. It involved a content analysis of public comments submitted to the U.S. Food and Drug Administration (FDA) in 2016 and 2017 in response to an invitation for feedback on the use of the term “healthy” on food labels (2).

Public comments about definitions of “healthy” generally mirrored the recommendations of the DGAs to promote a “healthy eating pattern”. Commenters emphasised the healthfulness of fruit, vegetables, whole grains, fish, and other minimally processed foods; and the need to limit added sugars, sodium, saturated and trans fats, and other ingredients sometimes added during processing.

A small number of commenters did not view any animal-source foods as part of a healthy diet. In addition, a few commenters (n=43) highlighted the importance of understanding what defines a serving and selecting an appropriate amount based on dietary needs to reduce overconsumption.

One-third of comments (n=374) referenced at least one dimension of sustainability, mainly the environmental dimension. These were related mainly to synthetic chemicals (such as pesticides) and genetic modification. Less than 20% of comments discussed social or economic dimensions of sustainability, and less than 3% of comments (n=30) used the word “sustainability” explicitly.

Some commenters raised concerns about the influence of the food industry within government policymaking and rulemaking and/or stated that they believe there is a conflict between food industry profits and public health goals.

The authors concluded that the results added to recent evidence suggesting that public comments can provide useful data for public health nutrition research. The FDA has not yet finalised the new definition of the term “healthy” and is actively developing a symbol that the food industry can voluntarily use to label food products that meet the updated definition of “healthy” (3).

The dataset used in this study may limit the validity of the findings as the portion of the population that was aware of this government consultation and motivated to submit a comment is unlikely to be representative of the U.S. population.

Reference

  1. Belarmino EH, Carfagno M, Kam L, Ifeagwu K-C, Nelson ME, Seguin-Fowler RA. Consideration of nutrition and sustainability in public definitions of “healthy” food: An analysis of submissions to the U.S. Food and Drug Administration. Public Health Nutrition. Published online 2024:1-25. doi:10.1017/S1368980024000636
  2. U.S. Food and Drug Administration. 2016. Use of the term ‘“healthy”’ in the labeling of human food products; request for information and comments. Regulations.gov. Available at https://www.regulations.gov/document?D=FDA-2016-D-2335-0001 Accessed 2017 Jun 25.
  3. U.S. Food and Drug Administration. 2022. Use of the term healthy on food labeling. Available at https://www.fda.gov/food/food-labeling-nutrition/use-term-healthy-food-labeling. Accessed 2023 Sept 5