Re: Docket No. FDA-2016-D-2335; Food Labeling: Nutrient Content Claims; Definition of Term “Healthy”

FDA-2016-D-2335; Food Labeling: Nutrient Content Claims; Definition of Term “Healthy” The Center for Science in the Public Interest (CSPI) commends the Food and Drug Administration (FDA) for issuing a proposed rule that would substantially improve the definition of the term “healthy” and better align the claim with evidence-based nutrition guidelines. [...] population) are “impacted by the use of the “healthy” nutrient content claim in a meaningful way to adhere to the Dietary Guidelines,” thus confirming the agency’s lack of confidence in any comparable population-wide benefits from updating the claim.8 Mandatory front-of-package labeling is the best way to leverage food labels to promote healthier diets and should be FDA’s top priority. [...] Only whole fruits and vegetables should count toward FGE of fruit and vegetables for foods to qualify as “healthy.” Concentrated purees, pastes, and especially 100 percent juice should not count toward FGE of fruit and vegetables for the same reasons that FDA has decided not to count powders—their processing typically removes some of the beneficial characteristics of whole fruits and vegetables. [...] For example, where “healthy” appears on the front of a cereal product that is described elsewhere on the label or labeling as high in dietary fiber (e.g., on the back of the package, or on a website), the “healthy” claim would constitute a nutrient content claim.” CSPI supports this broader interpretation of when a “healthy” claim constitutes a nutrient content claim. [...] Although the “healthy” definition may not need to be amended with every update to the DGA, we urge FDA to review and (if needed) revise the rule every five years to ensure the criteria used for the “healthy” claim continues to be based on the current scientific evidence and latest edition of the DGA.