ACS CAN provided comments in response to a U.S. Food and Drug Administration (FDA) request for information on the use of the term “healthy” on food labels.
ACS CAN supports updating the criteria for "healthy" to be consistent with current research and dietary guidance. If defined appropriately, “healthy” can be a tool to help consumers identify choices that support long-term health, including reduced cancer risk.
In summary, we recommend that FDA consider the following principles and recommendations in updating its criteria for use of the term “healthy” on food labels:
- The term “healthy” should help to guide Americans toward food categories and subcategories that are part of a healthy eating pattern, as defined by the 2015-2020 Dietary Guidelines for Americans.
- Within a food category, “healthy” should help to identify foods and beverages in their most nutrient-dense forms.
- “Healthy” foods and beverages should both 1) provide at least a minimum amount of food from a food group that is part of a healthy eating pattern, and 2) not exceed recommended limits for certain nutrients.
- Foods that are part of a healthy eating pattern include fruits, vegetables, whole grains, fat-free or low-fat dairy products or fortified soy beverages, and certain protein foods, including fish and seafood, lean poultry, eggs, legumes, nuts, seeds, and soy products.
- The presence of positive nutrients should not be allowed to substitute for foods that are part of a healthy food pattern. If the updated “healthy” criteria requires foods and beverages to provide a minimum amount of a positive nutrient, qualifying nutrients should be the nutrients of public health concern in the Dietary Guidelines, or protein, and ideally occur naturally in the food and not be added through fortification.
- “Healthy” foods and beverages should meet specified limits for added sugars, saturated fats (with exemptions for some foods like avocados, nuts, and fish naturally high in saturated fat), trans fats, sodium, and cholesterol. Limits on total fat are no longer needed.
- Red meats, processed meats, and sugar-sweetened beverages should not be labeled “healthy” because regular consumption of these products directly increases the risk for cancer or for obesity, which increases the risk of several cancers.
- FDA should conduct research on the use by industry of terms that may be considered alternatives to “healthy”, consumer understanding of such terms, and their impact on consumer behavior. Use of other terms that consumers understand to mean “healthy” should be considered implied healthy claims and subject to the same criteria, to the extent allowed by law.
- Use of the term “healthy” should help to reduce consumer confusion regarding which foods and beverages are truly healthy. FDA should encourage the food and beverage industry to use the term “healthy” on products that meet the definition and increase the number of new or reformulated “healthy” products in the marketplace.