**Global Food IQ is joining Eat Well Global for an expert Q&A on FOPL in early December! We’d love your input to make sure the conversation is relevant to you. Submit questions and sign up to receive a recording of the event here: https://info.eatwellglobal.com/fopl-qa-signup**
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Today, the Reagan-Udall Foundation held a virtual public meeting on front-of-pack labeling (FOPL), as the U.S. Food and Drug Administration (FDA) mulls new regulations.
ICYMI, FOPL has taken the global nutrition policy world by storm, with various warning labels, ranking schemes, and colorful icons popping up in every region. These labels aim to simplify back-of-pack nutrition information, encourage consumer purchases of healthier foods and beverages, and motivate innovation and reformulation by food manufacturers.
The U.S. has been much slower to explore FOPL regulations. In 2010 and 2012, the National Academies published two Congressionally-mandated reports with recommendations for effective FOPL systems. Ultimately, FDA opted to exercise enforcement discretion for the industry’s voluntary, self-regulated Facts Up Front label. Purely informational systems like these, without interpretive elements that make judgements about a product’s healthfulness, largely have fallen out of favor with governments and public health advocates.
Since that decision, FDA has conducted a literature review and several consumer research studies to further determine what type of government-led FOPL might work in the U.S. Today’s public meeting was designed to share FDA’s latest progress and hear from the public on three specific topics: FOPL design considerations, broader nutrition policy intersections, and international experiences. Below are Global Food IQ’s quick impressions from the meeting, including early thoughts on a potential FDA proposal.
- Advancing proposed regulations is a high priority for FDA. FDA Commissioner Dr. Robert Califf reiterated that FOPL is a key initiative featured in the White House Conference National Strategy, and that FDA believes FOPL can help achieve the agency’s goals to improve chronic disease, as well as equity in food and nutrition policy. No specific timeline for action was provided, but keep an eye out for a proposed rule in 2024. There’s a good chance FDA will propose mandatory enforcement based on global headwinds and available evidence.
- The proposed FOPL format may end up being interpretive, monochrome, and relatively simple. FDA’s latest experimental study tested several FOPL schemes: a monochrome informative label; an interpretive “high/medium/low” label with Daily Values (DVs), with and without traffic light colors; an interpretive “high/medium/low” label without DVs, with and without traffic light colors; and a “high in” monochrome, warning-type label with and without DVs. Published research has yet to confirm a “best” system, but there is traction around labels that are simple, interpretive, and government-created. While there is evidence to support colors helping to inform consumer choice (and many countries use these labels in Europe and Asia), few public commenters explicitly advocated for colored schemes. Conversely, many groups argued in favor of black and white, monochrome options. It’s also worth noting that Canada, a country with whom the U.S. sometimes coordinates regulations, chose a mandatory, “high in,” black and white FOPL scheme with a magnifying glass.
- Whether the FOPL nutrient profile should include only “nutrients to limit” or those plus “nutrients to encourage” is an important open question. FDA’s latest research only tested FOPL schemes that include saturated fat, sodium, and added sugars. While you can count on any FOPL proposal including these three nutrients, there was healthy debate during the public meeting about whether they are enough to help consumers build healthy dietary patterns. The absence of calories and “nutrients to encourage” like fiber or potassium removes the element of nutrient density from the equation. There was broad commenter support for including calories in the FOPL, but positions differed on nutrients to encourage. Additional nutrients and ingredients may end up in the mix – there were several calls to include low- and no-calorie sweeteners, like current approaches used across LATAM.
Global Food IQ can help you navigate U.S. and global FOPL regulations. It is essential to create and implement a cohesive and consistent strategy, so that your FOPL engagement around the world is evidence-based, meaningful, and makes sense for your business. We have experience developing advocacy strategies, stakeholder engagement plans, and strategic communications in this space. Reach out for more information and to schedule a meeting.
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