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Is This Healthy? How Food Product Data Can Mitigate Misinformation

Consumer Confusion and Misinformation

A popular question people ask when shopping for food products is, “Is this healthy?” Unfortunately this question is difficult to answer because consumers often have a limited nutrition education and lack adequate information. There is an enormous amount of misinformation in the marketplace, and consumers can be confused because of misleading information as well as genuine disagreements about which dietary patterns or ingredients promote health.

Consumer confusion is not surprising when one takes a look at the many inconsistent statements that are made publicly with respect to specific foods or diets. For example, the following headlines were just a few of those reported in the last year about the keto diet:

In her groundbreaking critique of the food industry entitled What to Eat, Marion Nestle stated the problem as follows: “The foods that sell best and bring in the most profits are not necessarily the ones that are best for your health, and the conflict between health and business goals is at the root of public confusion about food choices. Where diets get confusing is in the details: so many nutrients, so many foods.” Since even experts disagree about what is healthy, a substantial opportunity exists for consumers to be misled by the food industry, as many consumers don’t have a full understanding of what health claims mean or whether they are true and accurate.

Pro-Consumer Initiatives

For these reasons, the process of finding “healthy” foods can become overwhelming and cause many consumers to stray from their intended goals. Consumer advocates believe that intervention is needed in order to protect these consumers and further the national policy of promoting everyone’s health. It can take many forms, including educating consumers, enacting legislation clarifying what is considered healthy and making it easier for consumers to find healthy foods, and enforcing regulations that impose more rigorous requirements for producers to be able to label their food as a healthy option.  

A. Government Guidance and Requirements

“Healthy” is a subjective term because food products can affect different people differently and recommendations  often vary on what is best. The U.S. Department of Health and Human Services has explicitly recognized this by acknowledging that “Nutrition isn’t one-size-fits-all, so the [federal government’s] Dietary Guidelines offers a framework that people can use to find a dietary pattern that works for them.” In other words, there is no litmus test for eating “healthy.” Rather the federal government (acting through the U.S. Food and Drug Administration (“FDA”)) has traditionally followed the model of using a generalized food pyramid showing relative amounts of different food groups to be included in the daily diet as well as ranges of daily recommended allowance of particular ingredients. These guidelines are not static, but rather have continued to evolve as new scientific findings about food and diets are made. The current iteration is no longer a pyramid, but a food-plate layout called “MyPlate,” consisting of different sized portions of vegetables, grains, protein, fruits, and dairy.

Although these guidelines serve a useful purpose, they do not provide the consumer with insight on the healthiness of particular food products created by different brands. For that information, the consumer ordinarily would look to the Nutrition Facts label on the food packaging. That label is intended to help consumers make informed choices about the foods they select. In the words of the FDA, “You can use the Nutrition Facts label to monitor calories and nutrients in packaged foods and drinks and more often choose items higher in dietary fiber, vitamin D, calcium, iron, and potassium and lower in saturated fat, sodium, and added sugars.” 

However, expecting that consumers have the time or ability to read the Nutrition Facts label each time they buy a food product and interpret it for their personal situation is not always realistic. 

B. Visual Symbols and Seals; New FDA Study

To reduce consumer confusion and help them to identify “healthy” options more easily, it has become common to use visual symbols or seals on food products that meet specific industry or legal standards, such as Non-GMO Project, Certified Gluten-Free, Certified Vegan, Certified Plant-Based, USDA Organic, and Whole-Grain. These certainly help but aren’t enough because they don’t give a complete picture of health impact. Since 2018, the FDA has pursued a policy initiative known as the “Nutrition Innovation Strategy” in which it has identified priorities aimed at improving public health and “reducing the burden of chronic disease” through improved nutrition. 

To advance these objectives, the FDA is currently investigating whether a graphic symbol can be designed to assist consumers in being able to readily determine if packaged food products satisfy a standardized nutrient content-based definition of “healthy.” Once approved, such a symbol can be used by manufacturers on a voluntary basis for complying products. On May 21 of this year, it issued a public notice inviting comments on its plan to collect information for a study entitled “Quantitative Research on a Voluntary Symbol Depicting the Nutrient Content Claim ‘Healthy’ on Packaged Foods.” The FDA has stated that this research project is part of its ongoing efforts to facilitate consumers’ ability to make “informed dietary choices and construct healthful diets.” Results of the study will be used to help design a symbol that a manufacturer can voluntarily choose to place on food labels to represent that its product is “healthy” from a nutritional content standpoint. 

The FDA’s research study should be of substantial interest to manufacturers and grocers. Assessing consumer responses to the proposed graphic FOP symbols and refining those symbols to optimize such responses is likely to be instructive about different ways to make healthy products more identifiable to consumers. If the FDA study can result in one or more visual symbols connoting that a food product meets generally-accepted objective criteria for being healthy, that will help reduce consumer confusion and theoretically increase sales through increased consumer confidence and easier product discovery. Additionally, the study may lead to a better understanding of what consumers are looking for in terms of product attributes and thereby contribute to the efforts to improve online product search functions. 

C. Legislative Efforts

Efforts to help consumers eat healthy and avoid allergens are also being made through legislative initiatives. A proposed bill known as the Food Labeling Modernization Act (FLMA) is currently pending in Congress. If adopted, it would impose new requirements for front-of-package food labels and ingredient lists (including clear labeling of allergens), and make them more consumer-friendly. This proposed legislation should be of interest to food producers and grocers because of the new technical requirements with which they would have to comply and because of the light it sheds on the importance of brands responding to allergen concerns. It is also possible that the new law might lead to additional product attribute terminology that could result in added searchability of packaged food products.

Foodspace Can Help Online Grocers and Brands

Both of these pending initiatives have a direct bearing on the quantity and quality of information that consumers have with respect to packaged food products, the ease with which products can be searched and discovered, and the degree of confidence consumers have at the point of purchase. As a result, they have the potential to significantly affect sales. This is precisely where Foodspace can help. By assisting brands and online grocers to optimize product attribute descriptions and product label information, Foodspace can improve the product searchability and discovery functions that are so essential to online grocery shopping. Without discovery there is no sale, and without searchability the chances of discovery are greatly diminished.  

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