Comment on FDA’s 30-day Notice Regarding Quantitative Research on Front of Package Labeling (FDA-2023-N-0155)

For this task, we recommend that FDA include a no- scheme control to allow for comparisons of the effects of the FOP schemes to the status quo. [...] Of the three outcomes, we believe that participants’ ability to correctly interpret the nutritional profile of the product is the most important because it is the only one that is independently and objectively desirable. [...] Use the same nutrient profiles for healthiest, middle, and least healthy products across FOP schemes The document titled “Appendix E—Front of Pack Nutrition Labeling Experiment and Pretests 1 & 2 Questionnaire” includes the Nutrition Facts labels that will be linked to the healthiest, middle, and least healthy versions of each FOP scheme during the Comparison Task (Figure 4).9 Under the present pr. [...] These inconsistencies could result in the Comparison Task having different levels of difficulty for participants in the GDA and Nutrition Info scheme compared to participants in the High In 4 scheme, making it impossible to accurately assess the relative usefulness of GDA or Nutrition Info schemes compared to High In schemes in supporting consumers’ understanding of product healthfulness. [...] We recommend that FDA either remove this condition from the study and review the existing literature to examine optimal placement of FOP schemes, or alternatively randomize participants within each scheme to either see the label placed on the top right or bottom right of the front of pack, which would allow FDA to compare the effects of placement across all label schemes.