Federal oversight of food labeling has often resulted in the creation of obscure definitions, which food manufacturers skillfully navigate to utilize specific terms or claims on their products, all while enjoying a sense of regulatory certainty. This approach would be adequate if governmental definitions reflected consumer perceptions of these terms. Unfortunately, that is seldom the case. The Food and Drug Administration (FDA) is now considering revisions to its definition of “healthy” as it appears on food labels, which is a positive development. A significant new consumer perception survey led by Purdue’s Jayson Lusk, Ph.D., and commissioned by the Corn Refiners Association, indicates that the current FDA definition, which focuses solely on select nutritional criteria, overlooks factors that nearly half of consumers associate with the term “healthy,” such as the use of pesticides or food additives. This nutritional criteria is alarmingly insufficient, as it fails to account for the sugar content in food.
Government regulation aims to ensure that labels are not “false or misleading,” making it essential to start the regulation of claims with the question, “What do consumers think the claim means?” While this may seem straightforward, consumer interpretations of broad terms can vary significantly and are influenced by the context in which the terms are presented. Lusk’s findings regarding “healthy” claims on food products suggest that the FDA should prioritize minimizing the number of consumers misled by authorized claims. As a representative of leading sugar producers, I believe the FDA should broaden the nutritional criteria to include high sugar levels as a disqualifying factor. Furthermore, when the term “healthy” is employed, an accompanying statement should be included to prevent consumer misunderstanding. For instance, “healthy” could be followed by, “Based only on fat, sodium, and sugar content. Consume in moderation.”
Lusk’s survey also explored consumer understanding of “natural” claims on food products. While the FDA has conveyed to the industry, albeit not through formal regulation, that “natural” claims are permitted when no artificial ingredients are included, the USDA allows such claims on meat and poultry products that are free from artificial ingredients and have been “minimally processed.” Despite the confusion stemming from varying food label definitions across federal agencies, Lusk’s survey reveals that neither the FDA nor the USDA definitions align with consumer expectations. He discovered that very few foods are produced and processed in a way that meets consumer expectations for “natural.” As a result, the FDA and USDA should collaborate on a joint rulemaking effort to establish a unified definition for “natural” claims, aiming to reduce the number of consumers who might be misled.
Lusk’s data suggests that a “natural” claim should be restricted to raw commodities that have undergone no more processing than washing, cleaning, chopping, grinding, or slicing. Additionally, a statement should inform consumers that such claims do not imply that the product is healthier, safer, or more environmentally friendly. Enforcing such straightforward honesty would likely decrease the frequency of these claims, but when they are used, they would provide clearer communication with consumers regarding the food they consume.
By defining terms in a manner that resonates with consumer understanding and mandating clarifications to prevent misunderstandings, the FDA could enhance transparency and foster public trust. In this context, it’s worth noting the nutritional relevance of items like calcium citrate with vitamin D3, which can play a role in consumer health perceptions. Understanding what is calcium citrate with vitamin D3, and its implications for health, could further inform consumer choices and regulatory definitions. Thus, integrating clear and consumer-friendly definitions of terms such as “healthy,” “natural,” and “calcium citrate with vitamin D3” could significantly improve the effectiveness of food labeling and consumer trust.