The Food and Drug Administration is soliciting feedback on its attempts to develop a consistent definition for the term “healthy,” which companies can use on their products. In comments submitted today, IDFA told FDA that the term “healthy” could be used in many ways and urged the agency to set criteria for a “healthy” claim specifically for dairy foods, taking into account the full nutrient profile and dietary contributions of dairy.

Healthy Dairy Category

In keeping with nutrition research and recent public health recommendations, IDFA told FDA there should be no limit on total fat in specific nutrient criteria for all dairy foods. “It is more important to focus on the type of fat, rather than the total amount,” IDFA said.

The association proposed the following points for dairy products making “healthy” claims:

  • There should be no limit on saturated fat when the source of saturated fat is milkfat;
  • If FDA decides not to exempt milkfat from counting toward any saturated fat limit, FDA should include all low-fat and fat-free dairy in the definition of "healthy; and
  • Milkfat should be considered differently from other saturated fats.

Added Sugars

IDFA also suggested that added sugars should be considered together with the full nutrient package they accompany. The association recommended FDA allow healthy content claims for flavored milks with less than 13 grams added sugar per eight-ounce serving, flavored yogurts with less than 23 grams of total sugar per six-ounce serving and other dairy products with less than 35 percent total sugar by weight.

As with added sugar, IDFA suggested that sodium content needs to be considered based on function and overall contribution to a healthy diet. “Setting low sodium limits for cheese in order to meet a ‘healthy’ definition could actually reduce consumer demand for these products through adverse impacts on quality, and in some cases the safety of the product may be seriously adversely affected,” said IDFA. “Since cheese contributes less than 4 percent of sodium intake to the diet, it is not necessary for cheese to have lower sodium levels in order to contribute to a healthy diet.”

In addition, IDFA recommended all dairy products using healthy claims be at least a good source of calcium, protein or vitamin A. IDFA also encouraged FDA to use the Reference Amount Customarily Consumed (RACC), which reflect the actual serving sizes of foods Americans consume, as the basis for determine if a dairy food is “healthy” in the amount it is eaten.

“Healthy” in General Use

To ensure clarity, IDFA asked FDA to allow companies to use healthy in more general uses on labels, in additional information provided to consumers or in broad dietary guidance statements. IDFA believes products with claims such as “part of a healthy breakfast” should not have to meet the nutrient requirements of “healthy” food claims.

IDFA concluded that the suggested category and criteria for healthy dairy products would help encourage the consumption of dairy foods while also helping consumers select the options that meet their health, taste and lifestyle needs.

FDA will review the many comments submitted by interested parties, but it is not known when the agency will issue specific changes to the current regulations.

Read IDFA's comments here.

Members with questions may contact Cary Frye, IDFA vice president of scientific and regulatory affairs, at cfrye@idfa.org and Michelle Matto, IDFA’s consultant on nutritional and labeling, at amfoodnutrition@gmail.com.