IDFA Urges FDA to Proceed with Caution on Potential Daily Values Updates
In comments filed last week with the Food and Drug Administration (FDA), IDFA opposed making changes, at least for now, to the reference values that the agency uses to calculate the percent Daily Values listed on the Nutrition Facts Panels on all food and beverages. Instead, IDFA urged FDA to approach label changes with caution to ensure that they are based on strong science, understood by consumers, promote positive dietary changes and have no unintended consequences.
IDFA believes that making changes to the Nutrition Facts panel would be a premature step, because the various stakeholders are still at odds over the most appropriate way to set Daily Values.
"Any final rule defining Daily Values for use on food labels should be postponed until nutrition, labeling and consumer behavior experts come to significant agreement about how the Daily Values should be determined," the comments state.
In its advanced notice of proposed rulemaking, FDA specifically asked for comments, along with scientific justification, on how the agency should set Daily Values and whether consumer use and understanding of current values should be used as a benchmark for determining updates and changes. FDA has not updated or developed new Daily Values since 1995.
IDFA recommends using different approaches for updating the values, depending on the nutrients involved. For carbohydrates and fats, whose main nutritional roles are to provide calories, IDFA suggests updating the Daily Values by using scientific ranges that are based on energy requirements. For protein, IDFA recommends using the Recommended Daily Allowances, which would encourage optimal intake levels, because emerging nutrition research shows that higher levels of protein intake are beneficial to all diets. For vitamins and minerals, IDFA recommends basing the Daily Values on the average needs of the American population.
IDFA also warns that any updates to the Daily Values should have a minimal impact on nutrient-dense foods that make nutrient content claims, such as "good source" or "excellent source" claims. Otherwise, the changes could make nutritious, nutrient-dense foods, such as milk and dairy products, appear less healthy.
While some companies may choose to reformulate products to maintain levels of nutrients to qualify for nutrient content claims, that option would not be allowed or feasible for all nutrients or food products.
"Product reformulation would penalize foods that pride themselves on being naturally nutrient rich," the comments state. "If a food is naturally a good or excellent source of a nutrient, product reformulation to increase levels of that nutrient is not easily done."
Looking ahead to implementation, IDFA urges FDA to take steps to reduce consumer confusion during the transition period when the new Daily Values would be introduced. One way would be to require all mandatory changes to be made at one time. This timetable would help processors to make single changes to labels, thereby reducing costs, and would allow all changes to be included in one communications program for educating consumers.
IDFA presented extensive comments, because the proposed rule has the potential to involve label changes for every single product that has a Nutrition Facts panel, including nearly all dairy products. To read the comments, click here.
For more information, contact Michelle Matto, IDFA assistant director of regulatory affairs at mmatto@idfa.org or 202-737-4332.