Proposed Major Revision to Food Nutrition Facts Labels

Proposed Major Revision to Food Nutrition Facts Labels

The Obesity Society (TOS) Supports All Proposed Changes to Food Nutrition Facts Labels and Commends the US Food & Drug Administration (FDA) for the Much-Needed Update

TOS Comment on the FDA Proposed Rule, Food Labeling: Revision of the Nutrition and Supplement Facts Labels

May 15, 2014

The U.S. Food and Drug Administration (FDA) recently announced proposed changes to food nutrition labels - the first major update since the labels originally appeared in 1993. According to the FDA, the goal of the proposed changes to the Nutrition Facts label is "not to tell people what they should be eating, but to expand and highlight the information they most need when making food choices." Given the amount of conjecture, even amongst experts, about what constitutes an optimal diet, The Obesity Society (TOS) believes this goal to be appropriate. Further, we believe that through the proposed nutrition label, the FDA is making progress toward this goal.

While studies to date show that, on average, providing nutrition information may have relatively small effects on the calorie content of purchases, there remains a possibility of meaningful change from providing easily understandable information for consumers.1-4 Notably, even if customers do not directly respond to this information, food manufacturers may, thereby improving the health content of food offered. Some preliminary evidence has demonstrated this effect with calorie menu labeling implemented several years ago in Seattle.5 Further, this is a positive public health measure with a very low likelihood of harm and, for these reasons, TOS supports the proposed revisions.

It is vital that the proposed changes result in a more user-friendly delivery of the most important nutritional information. Further, it is particularly important that the FDA address a loophole (resulting from steadily increasing portion sizes), which allows manufacturers to report nutrition facts for only a portion of the food or beverage typically consumed in one sitting. For example, manufacturers of 20 oz. soda bottles report nutrition facts for only 40% of the bottle (deemed one serving) despite the fact that consumers typically view the entire bottle as one serving. If the nutritional information and consumer perceptions of serving sizes don't match, consumers may underestimate calories and sugar content.

The FDA has proposed 4 major changes to the current Nutrition Facts label. TOS endorses all of them:

  1. "Serving Size" will be adjusted to more accurately reflect what people normally consume. For example, consumers will now see nutrition information for a full 20 oz. bottle of soda instead of just 40% of the content (note: several companies have already done this voluntarily) and a full cup of ice cream instead of 1/2 cup.
  2. "Calories" will be made much more prominent. With regard to the determination of body weight and the prevention/treatment of obesity, the number of calories consumed is the single most important piece of information contained on the Nutrition Facts label. Thus, we wholeheartedly agree with the proposed nutrition facts label design that will emphasize calorie content.
  3. "Added Sugars" will be reported. Manufacturers will now need to report the amount of sugar they add to food and drinks. We hope this will not only help individuals become aware of the amount of added sugar they are ingesting (e.g., 1 can of sugar-sweetened soda has 8 teaspoons, while the recommended daily amount for women is only 6 teaspoons), but also motivate manufacturers to start lowering the amount of added sugars in products.
  4. "Total Fat" will no longer be reported. There is concern that the reporting of total fat may give the implication that all fat is equal, which is inconsistent with the scientific literature. Unsaturated fats have been shown to raise good cholesterol (HDL) and lower bad cholesterol (LDL).6 Conversely, trans and saturated fats traditionally have been associated with increased LDL cholesterol and unhealthy weight gain.7,8 The removal of total fat as a category on the Nutritional Facts panel acknowledges these important facts.

Several other minor changes have been proposed, including making servings per package more prominent, updating "Daily Values," and including amounts of potassium and Vitamin D. Unfortunately, it will be more than two years until we see the new labels in stores as a result of a grace period granted to manufacturers. Nonetheless, the changes proposed for the Nutrition Facts label are welcome. Americans are making progress in their recognition of health information, a fact that could, over time, contribute to the slowing of the incidence of obesity in the U.S. The FDA should encourage the provision of salient and easily understandable nutrition information. The proposed changes to current Nutrition Facts labels are an important step toward meeting this goal and the FDA should be commended for its efforts in this regard.


  1. Bollinger B, Leslie P, Sorensen A. Calorie posting in chain restaurants. Am Econ J Econ Policy. 2011;3:91-128.
  2. Auchincloss AH, Mallya GG, Leonberg BL, Ricchezza A, Glanz K, Schwarz DF. Customer responses to mandatory menu labeling at full-service restaurants. Am J Prev Med. 2013;45:710-9.
  3. Dumanovsky T, Huang CY, Nonas CA, Matte TD, Bassett MT, Silver LD. Changes in energy content of lunchtime purchases from fast food restaurants after introduction of calorie labeling: cross sectional customer surveys. BMJ. 2011;343:d4464.
  4. Elbel B, Kersh R, Brescoll V, Dixon B. Calorie labeling and food choices: a first look at the effects on low-income people in New York City. Health Aff 2009;Web exclusive:w1110-w21.
  5. Bruemmer B, Krieger J, Saelens BE, Chan N. Energy, saturated fat, and sodium were lower in entrees at chain restaurants at 18 months compared with 6 month following the implementation of mandatory menu labeling regulation in King County, Washington. J Acad Nutr Diet 2012;112:1169-76.
  6. Appel L, Sacks F, Carey V, et al. Effects of protein, monounsaturated fat, and carbohydrate intake on blood pressure and serum lipids: results of the OmniHeart randomized trial. JAMA. 2005;294:2455-64
  7. Trumbo PR, Shimakawa T. Tolerable upper intake levels for trans fat, saturated fat, and cholesterol. Nutr Rev. 2011;69(5):270-8.
  8. Hariri N, Gougeon R, Thibault L. A highly saturated fat-rich diet is more obesogenic than diets with lower saturated fat content. Nutr Res. 2010;30(9):632-43.