IDFA Urges FDA to Look Beyond Four-Tier Health Claims System

Food manufacturers should be allowed to use a broader variety of explanatory terms in qualified health claims on food products than allowed under the Food and Drug Administration's (FDA) four-category scheme, according to IDFA in its January 17 comments to the agency. The association submitted the comments in response to FDA's call for input after a November 2005 public meeting on how to assess consumer perceptions of qualified health claims on food packaging.

"The focus must always be on conveying accurate, truthful and non-misleading information to the consumer and not upon the use of some standardized terminology offered by FDA," states IDFA in the comments.

Under FDA's system, qualified health claims are rated based on the level of scientific backing from "A" to "D", with an "A" grade meaning there is "significant scientific agreement" on the claim; a "D" claim means that there is "little scientific agreement supporting this claim". FDA has also proposed standardized, formulaic phrasing for all health claims under the four-grade system.

IDFA pointed out that consumer research done by both FDA and the International Food Information Council (IFIC) found that people had "difficulty understanding the strength of the science behind qualified health claims" using the four-level ratings. In addition, the studies found a "disturbing effect" of the report card grading, where "consumers felt that the grade given to the science also applied to the quality, healthfulness and safety of the product making the health claim."

Regarding the standardized terminology, IDFA again urged FDA to not rely on the results of its test in which the agency tested generic food health claim messages, using hypothetical products, brands and marketing contexts; the association had asked FDA in February 2005 to abandon this testing protocol. Among IDFA's concerns about this approach is its belief that FDA would be overreaching to extrapolate the narrow results based on generic circumstances to form the basis of health claims policy. (For background on this topic, click here to read a previous news story.)

To read IDFA's full comments, click here. (.pdf) Members with questions can contact Michelle Matto at mmatto@idfa.org, 202/220-3523, or Cary Frye at cfrye@idfa.org, 202/220-3543.

Posted January 23, 2006