Hunger and obesity are two major food crises facing the United States.

According to the Food Research and Action Center (FRAC), one in eight households, or an estimated 44.2 million Americans, experienced food insecurity or lack of access to an affordable, nutritious diet in 2022. Meanwhile, FRAC reports that nearly 40% of adults are obese and another 31.6% are overweight, which can lead to chronic disease.

In September 2022, the White House National Strategy on Hunger, Nutrition and Health set down five pillars aimed at improving these problems and ensuring all Americans have access to healthy and nutritious food. They included improving food access and affordability by expanding programs like free school meals and the Supplemental Nutrition Assistance Program (SNAP) and integrating nutrition and health education through the Medicaid and Medicare programs. The strategy also supports physical activity, an enhancement of nutrition and food security research, and help for consumers to make healthy food choices.

Facilitating those healthy choices, according to a summary of the White House strategy, would involve “empowering all consumers to make and have access to healthy choices, including by proposing to develop a front-of-package (FOP) labeling scheme for food packages” and an update to the nutrition criteria for the “healthy” claim on food packages. It also calls for expanding incentives for fruits and vegetables in SNAP, facilitating sodium reduction in the food supply by issuing longer term, voluntary sodium targets for industry, and assessing additional steps to reduce added sugar consumption, including potential voluntary targets.

The Food and Drug Administration (FDA) has been working on FOP labeling and collecting information from a variety of sources to determine the best way to implement this policy. The agency plans to publish a proposed rule for nutrition labels this year to provide at-a-glance nutrition information that can help consumers identify foods that can help them make healthy choices.

“Food labeling can be a powerful tool in that it, for example, provides valuable information that can help consumers make more informed food choices,” said Robin McKinnon, senior advisor for nutrition policy at FDA’s Center for Food Safety and Applied Nutrition. “For instance, the Nutrition Facts label provides standardized nutrition information to consumers, and nearly 80% of US food shoppers use it sometimes or often. Using the Nutrition Facts label frequently is associated with healthier dietary patterns.”

These FOP labels would have an economic impact for sellers of packaged goods, including the cost to change packaging to add these labels as well as potential repercussions on sales if labels contain warnings that the product is high in sugar, sodium or fat.

In addition to holding meetings to develop FOP labels, the FDA completed a review of scientific literature, two rounds of focus groups and an experimental study, McKinnon said. Study results should be published later this year for public comment after an external peer review.

“We have also held meetings with a wide range of interested parties, such as consumers, public health advocates, academia and industry,” she said. “In addition, The Reagan-Udall Foundation for the FDA hosted a public meeting in November 2023 on FOP labeling, which allowed us to hear from a variety of interested parties. These meetings have given us insight into the ways these various parties are thinking about FOP labeling, their experiences with existing FOP labeling schemes and their general feedback on FOP labeling.”

The Food and Beverage Issue Alliance (FBIA), a coalition of more than 50 food and beverage trade associations, provided a letter of comments on the FDA procedural notice, “Quantitative Research on Front of Package Labeling on Packaged Foods,” dated March 27, 2023.

“If FDA moves forward with developing an FOP nutrition labeling scheme, it should not conflict with regulatory and trade obligations; should be grounded in adequate scientific evidence; should be clear, simple and flexible, and should facilitate consumer understanding,” the letter stated. “We also ask FDA to consider if the agency has the authority to require such a system be used on packaged food items versus voluntary programs.”

Among the main points the organization makes in the letter is the need for consistency across all nutritional labels.

“Any potential FOP nutrition labeling scheme should not conflict with national labeling regulations or dietary guidance (for example, Dietary Guidelines for Americans), and any FOP nutrition labeling scheme would need to be updated in tandem as national dietary guidance or labeling and trade regulations change,” the letter stated. “An FOP nutrition labeling scheme should support portion balance and variety, consistent with evidence-based national or regional dietary guidance.”

FOP labels should improve consumer understanding and equip consumers with information on the nutrient density of foods and should be flexible for manufacturers required to put them on packaging, the letter said.

“An FOP nutrition labeling scheme should be conspicuous, and there should be flexible formatting requirements for font size, style and placement, particularly in the case of small, unique and multi-market packaging,” the letter said. “Any FOP nutrition labeling scheme should not be applied to those foods exempt from bearing a Nutrition Facts Label.”

The letter also calls for a cost-benefit analysis of the labels.

“Recent regulatory changes that have required changes in almost all food labels, including revisions to the Nutrition Facts Label, the National Bioengineered Food Disclosure Standard and sesame allergen labeling have imposed billions of dollars of costs on the food supply, ultimately adding to consumer food cost,” the letter stated. “The purported benefits of those requirements were speculative and based on limited evidence. FDA should undertake a retrospective analysis of the cost and benefits that were projected to result from the 2016 rule requiring revisions of the Nutrition Facts Label. Such an analysis would inform projection of the costs and benefits of a requirement for an FOP nutrition labeling scheme.”

The Consumer Brands Association (CBA) said its member companies have shared costs for label changes that range from $1 million to $26 million, depending on the brand’s product portfolio. Any major label change for the industry will require three to five years for implementation, said Sarah Gallo, vice president of product policy for CBA.

Gallo said the CBA has worked with the FDA for more than a decade to improve nutrition facts, including efforts to update Facts Up Front guidelines, a voluntary industry-led initiative that puts key nutritional information from the Nutrition Facts panel on the front of food packaging.

“And through SmartLabel, an industry-developed digital disclosure tool, consumers can easily scan a QR code to access more detailed product information than could ever fit on a package,” Gallo said. “To provide the most consumer-friendly labeling, the FDA should continue to rely on collaborative efforts with industry and data-driven research. This requires a holistic approach, which should involve important nutrient information, including both nutrients to encourage and nutrients to limit.”

Among CBA member concerns of the FOP labels is the use of symbols on packaging.

“The FDA is currently considering schemes with arbitrary scales and symbols that could cause confusion among consumers,” Gallo said.