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Improving Nutrition Labeling: What you Need to Know

Center for the Global Food Value Chain Blog

U.S. consumers aren’t eating the way they used to, and the Food and Drug Administration (FDA) is aware of this. Innovation and improved manufacturing processes means consumers are eating different foods and in quantities that may be quite different than current labeled serving sizes.  

To make the nutrition label current and meet more consumers’ needs, the FDA realized regulations on nutrition labeling needs to change to reflect this new reality.  Changing the format and requirements of the nutrition label may have a profound effect on the future of acceptable nutrition and health claims and in turn significantly impact products and labels. Specific guidance from the FDA on these changes hasn't been released yet, but I foresee two areas that may potentially change: Daily Values (DVs) and Reference Amounts Customarily Consumed (RACCs).

The Institute of Medicine has published multiple Dietary Reference Intake metrics that may form the basis for new DVs. As of now, a minimum of 10% of the DVs of a nutrient is needed to make “good source” and “high” claims. If the DVs of a nutrient are increased, you may be required to add more of the nutrient to a product to keep the current claims on the label. If the DVs of a nutrient are decreased, it may become easier for you to make more accurate claims on nutrition, which may help you further differentiate your product in the marketplace.

Similar to DVs, RACCs may change based on amounts people are actually eating. Since RACCs are directly linked to nutrient content claims, increased RACCS may help you make more accurate claims on nutrients to encourage (e.g., calcium, fiber), but make it harder to make claims on nutrients to limit (e.g., sodium). Alternatively, smaller RACCs may make it harder to make claims on nutrients to encourage—and easier to make claims on nutrients to limit.  

These proposed regulations may be released in early to mid-2013. Enforcement may not start until about 2015.  

What does this mean for you today?  Once these rules go into effect, you may need to change your labeling portfolio, including adjusting the labeling claims or reformulate your products in order to meet the new requirements. These changes may have significant lead time associated with them, so plan and act accordingly. I'll be watching these developments closely to keep you informed in forthcoming blog entries.

Christie Gray
ERS Manager | Business Risk
Deloitte & Touche LLP

Caitlin Hickey
ERS Consultant | Business Risk
Deloitte & Touche LLP




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