The current issue of the Journal of Hunger & Environmental Nutrition includes a commentary co-authored by myself and public health attorney Michele Simon. The piece is a response to the recent – and ongoing – debate surrounding front of package labeling.


After the now-infamous Froot Loops “Smart Choices” fiasco of 2009, the Food and Drug Administration publicly announced its desire to partner with the food industry, nutrition experts, and the Institute of Medicine:

“to develop an optimal, common approach to nutrition-related front of package labeling that Americans can trust and use to build better diets and improve their health.”

Released in November 2010, the new guidelines simply took selected information from the Nutrition Facts label (e.g., calories, fat grams) and repeated it on the front.

In our article, we argue that despite claims that this “new” front-of-package labeling is meant to help Americans select healthier foods:

“It merely repeats what is already stated on the Nutrition Facts label of all packaged foods, does not address the most important causes of obesity and chronic disease, and allows food companies to reformulate products in such a way that they still deliver minimal nutrition and questionable ingredients.”

Suggestions to only list “nutrients of concern” – calories, saturated fat, trans fat and sodium – are also misguided and miss the bigger picture. After all, a low-sodium, free of trans fats but still highly refined chip or cookie, would be low in “nutrients of concern” but is nevertheless a marginally nutritious snack.

Moreover, obesity is far from the only health concern. Many Americans who are at a “healthy weight” do not consume the necessary amounts of many nutrients, most of which (i.e.: magnesium and potassium) are not found in highly processed foods.

Supporters for FOP labeling argue that it will force food companies to reformulate products, thereby improving the nutritional quality of commonly-consumed foods. However, this argument is flawed for many reasons, as we argue in the commentary.

– Re-formulation of processed foods is reactive, and does not necessarily yield a more healthful product.

– Replacing trans-fats with oils that high in omega-6 fatty acids (I.e.: corn oil, cottonseed oil) is a slightly better alternative, but not a healthful solution.

– Lowering sugar grams via the inclusion of artificial sweeteners does not promote good nutrition.

– Lowering milligrams of sodium in products that are already low in minerals essential for the regulation of blood pressure (mainly potassium and magnesium) is a moot point, particularly since plenty of nutrition research has demonstrated that increasing potassium intake – a mineral found in fruits, vegetables, whole grains, and legumes – is more effective than sodium reduction.

– Many processed foods bump up fiber grams by adding isolated fibers like inulin. While these fibers can ease digestion, they are not equivalent to a whole grain food, which offers minerals, phytonutrients, and antioxidants not found in these isolated fibers.

– Re-formulation provides a free advertising boost to food companies. A sugary cereal that decreases sugar grams per serving by one can now place a “Now with less sugar!’ claim on the front of their packaging, while products that are already – and always have been – healthful don’t get that advantage.

This past January, the Government Accountability Office added a voice of reason to the discussion with its report, Food Labeling: FDA Needs to Reassess Its Approach to Protecting Consumers from False or Misleading Claims, which successfully argued that FOP labeling confuses consumers and is ripe for food industry deception.

Weeks later, the Grocery Manufacturers Association – comprised of more than 300 food companies, including Cargill, Coca-Cola, and General Mills – along with another Big Food lobbying group – the Food Marketing Institute — released their own FOP labeling system (described as “monumental and historic”), called “Nutrition Keys.”


All products that participate in the Nutrition Keys system will display calories, saturated fat, sodium, and total sugars per serving – both in numerical and percentage form – as well as two “nutrients to encourage,” which can include fiber, potassium, vitamin A and, oddly enough, protein (the average American consumes more than sufficient amounts).

Despite the Nutrition Keys rehashing information already found on the Nutrition Facts label, a $50 million “consumer education campaign” is planned.

Since we submitted our article, the food industry has retooled its attempt to preempt the FDA, now calling its voluntary program, “Facts up Front.” Whatever its moniker, it’s not helpful and only serves industry interests.

Much like the “diet wars”, the debate over different FOP labeling systems distracts from more substantial issues that could address the root causes of our current epidemic of diet-related disease. America’s health would be better supported by more effective agricultural policies and curbing aggressive marketing than by the repetition of nutrition information on boxes of highly processed and minimally nutritious foods.

The full text version of the article is available for a fee. You can also read a short preview at no charge.


Andy Bellatti, MS, RD, is a Seattle-based dietitian who approaches nutrition from a whole-foods, plant-centric framework. He also takes a strong interest in food politics, nutrition policy, and deceptive food industry marketing tactics. “Front of Package Labeling: An Exercise in Futility?” was first posted Dec. 12 on his website, small bites.