The US FDA has proposed adding a “Nutrition Info” box (like the one in the illustration above) to the front of every food package. It would list the the amount of added sugar, salt and saturated fat per serving in the product. You can read more about the proposed regulations here. The proposed rule is open for public comment until July 15, 2025. Following are my submitted comments on this proposed regulation and suggestions on how we can create even better food labels:

Comments on FDA proposed Food Labeling: Front-of-Package Nutrition Information

Docket number FDA-2024-N-2910

I am a certified food scientist, and have been developing new food products and their labels for over 40 years.  I most definitely recognize the need for Americans to eat less salt, sugar and saturated fat.  However, I would like to suggest some changes to the proposed front of pack “nutrition info boxes” to make the system more understandable to the public and more workable for food companies.

• Create compatibility with Healthy regulations

According to new regulations for the use of the term “healthy”, effective April 28, 2025 (21 CFR 101.65), a “main dish” and “meal” are allowed to contain 20% and 30% DV sodium respectively.  Meals are also allowed to contain a maximum of 20% DV of both added sugar and saturated fat. 

This creates the confusing situation where main dish and meal items can be labeled as healthy, even though front of pack labeling would indicate they are high in sodium (and for meals saturated fat and added sugar).  To prevent consumer confusion, this disparity needs to be resolved.

• Clarify if “high” is good or bad

I understand that when testing proposed FOP label formats, consumers were able to identify products with a little or a lot of certain nutrients.  But do they understand if a lot is good or bad?

Current marketing of food products often highlights products that are high in or a good source of certain nutrients.  More or high (and “nutrient dense”) is considered a good thing.  Are consumers sophisticated enough to know that in the case of the proposed “Nutrition Info” boxes that “high” is bad?

In my experience, most consumers recognize too much salt and sugar is bad.  But saturated fat is controversial, even within the nutrition community and government agencies.

• Highlight nutrients to encourage

The proposed FOP labeling only describes what is NOT in the product.  This creates the illusion that products such as potato chips and artificially sweetened cakes and beverages, low in salt, sugar and saturated fat, but with no redeeming nutritional value, are foods to be encouraged.

On the other hand, for example, a vegetable and chickpea dish that is high in fiber, protein, vitamins and minerals might appear less healthy due to higher sodium or saturated fat content.

Dieticians stress that the entire dietary pattern is more important than individual foods.  This is why we have the entire Nutrition Facts panel.  Consumers can see the whole nutritional profile of the food, not just specific nutrients that are absent.

• Preserve effectiveness of Nutrition Facts panel

Consumers are already hopelessly confused about nutrition.  I’m afraid adding yet another box (with almost the same information) to the front of pack is not going to help the situation.  It is better to direct all nutrition questions to ONE place – the Nutrition Facts panel.  That way, consumers can see the entire nutrient profile and decide if a product is suitable for their personal situation.

In this case, additional education and/or Nutrition Facts panel updates should be considered to make it easier to understand which are nutrients to encourage and discourage.  In other words, how to make it obvious to a lay person that more sodium is bad, but more fiber is good?  Or that total fat might be okay but saturated fat is bad?

First and foremost, it is important for consumers to know that the Nutrition Facts Panel is the part of a food label where it is hard for food companies to lie.  This is the ONE place they should go for factual information about the product.

• Conserve label space

Anyone who has been involved with food label design will tell you, there is never enough space.  Fitting in all the required information without making the label look cluttered or confusing is very difficult.  Boxes of cereal and bags of frozen vegetables are the exception, but most products are in the “medium” (40-100 sq inch) size range.  And space is at a huge premium.

Even the smaller proposed “Nutrition Info” box takes up a lot of space.  This is especially problematic on the front of pack.  The front of pack must contain the brand name, the product name, net contents and some depiction of the product so the consumer knows what it is.  There is simply very little space left.

Having to include the Nutrition Info box on front of pack is particularly onerous for products low in salt, sugar and saturated fat.  Especially considering the information is duplicated in the Nutrition Facts panel.

• Bring back the Disclaimer

I suggest 1) alerting consumers about foods high in saturated fat, sodium and sugar, and 2) focusing nutrition information in one place on the label, by bringing back a “disclaimer” system similar to the one required on foods with claims in the 80’s and 90’s.

Complete nutrition information would be in ONE place on the label: the Nutrition Facts panel.  BUT, any product with more than 20% DV of saturated fat, sodium or added sugar would be required to declare it on the front of pack.

This disclaimer could take the form of colors or symbols or simple text such as “This product is high in saturated fat, see Nutrition Facts for more information”.

A disclaimer system accomplishes several critical objectives:

• It is easily understandable by consumers.  They don’t have to learn how to read the box.  Disclaimers are ONLY on products high in salt, sugar or saturated fat.  And consumers are directed to the Nutrition Facts panel for complete information.
• It is not duplicative and maintains the integrity of the Nutrition Facts panel as the one and only source of complete nutrition information on the label.
• The burden of adding the disclaimer is borne only by food products which are high in salt, sugar or saturated fat.
• It saves label space.  More healthful products (with less than 20% DV salt, sugar and saturated fat) do not require extra labeling.
• The disclaimer requirement can be tailored to accommodate “main dishes” and “meals” to align with current regulations for the use of the term “healthy”.  This will avoid the confusing situation of a product labeled both healthy and high in undesirable nutrients.