It is one of the ironies of marketing that the healthiest food often isn’t labeled as such at our retail supermarkets.

At the same time, some of the least healthful foods glom the fruit and vegetable halo with only minute ingredients.

It is to that reality that the United Fresh Produce Association has submitted comments on the “The Food and Drug Administration’s Comprehensive, Multi-Year Nutrition Innovation Strategy; Public Meeting; Request for Comments.”

In comments dated Oct. 11, United Fresh’s Mollie Van Lieu, senior director of nutrition policy, provided a response to FDA’s call for comments. Here are some excerpts:

Every time a consumer goes looking for healthier food and is sold a food or beverage that undermines their health, that is a missed opportunity to reduce diet-related disease. 

Many consumers who dutifully try to follow dietary advice nonetheless struggle with excess weight gain, high blood pressure, prediabetes, and other preventable diet-related health problems. Data from the International Food Information Council show that health, as well as weight loss, are core considerations for most consumers in making food choices. Consumers pay attention to labels: more than half of consumers look at the Nutrition Facts Panel or ingredient list “often” or “always” when making a purchasing decision, and approximately 40% say they consider other labeling statements about health or nutrition benefits.

Healthy Label

Labels provide actionable information at the point of decision, connecting dietary choices to health. Yet products across the marketplace can be marketed to make food and beverages appear more healthful than they are. Specifically, consumers should not be misled that processed foods like sugar-laden cereals and salty snacks with images of fruits and vegetables are adequate dietary substitutes for fresh fruits and vegetables. For this reason, FDA has an opportunity to address potentially misleading or inaccurate labeling claims that may enable unhealthy foods to unfairly compete with fresh fruits and
vegetables, which occupy too little space in Americans’ diets.

When considering labeling policy, it is particularly important to note that unpackaged fresh fruits and vegetables often bear no labels at all. Accordingly, whilea FDA-defined healthy logo holds potential to be useful for consumers for packaged foods, it could have an unintended consequence of signaling to consumers that a packaged product with an icon it is a better choice than unpackaged commodities like fresh fruits and vegetables.

Meaningful Amount

The FDA also expressed an interest in exploring claims for products that Americans often fall short of consuming, including considering how claims could or should signal that a product contains a “meaningful amount” of these food groups. To create more clarity for consumers, we encourage the FDA to consider requiring clear, transparent declarations on foods making fruit and vegetable claims that would allow consumers to understand how these products do, or do not, contribute to a healthy dietary pattern.

A “meaningful amount” of fruits and vegetables should not allow claims based on powders, juices, purees, pastes, and concentrates, which are not as nutritious as whole fruits or fresh-cut because they lack the low-calorie density, cell structure, intact fiber, and other factors that contribute to the healthfulness and satiety of whole or cut up fruit. Permitting “meaningful amount” claims for these ingredients could appear to inflate the minimal nutritional value of options that are less nutritious than real fruits and vegetables, and therefore undermine Americans’ efforts to eat more healthful foods.

Deceptive Labeling

We encourage the FDA to review the most frequently employed claims with implications for public health, including “made with” and “contains real fruit” claims, the use of misleading images of whole fruits and vegetables when only minuscule amounts are in a serving, the use of misleading titles for categories of foods that are unhealthy or are minimally nutritious foods (i.e., “Veggie Sticks,” “Fruit Snacks”). The agency should consider whether, taken as a whole,such labels, images or claims are misleading or deceptive.

Instead, we urge the FDA to address this issue by:

• Consider requiring foods making fruit and vegetable claims (through words or depictions) disclose the quantity of fruits and vegetables per serving in household measures (e.g., “contains 1/8 teaspoon of strawberries per 1-cup serving”). The declaration should be specific to the type of fruit or vegetable depicted or mentioned in claims, to avoid creating a lack of transparency that unfairly depicts that more desirable or expensive ingredients (e.g., “spinach” or “strawberries”) predominate in a food when they do not.

• Foods that contain fruit or vegetables that are not in their whole or cut form (without added sugar or sodium) should not be counted towards the amount of fruit in the declaration (for example, powders, concentrated fruit juice, or purees). A required disclosure should additionally indicate that the “The Dietary Guidelines for Americans recommends that at least half of your daily amount of fruit intake should be from whole fruits.”

• If a food is lacking in fruits and vegetables and contains only fruit or vegetable flavoring, it should bear a disclosure: “Contains no real fruits/vegetables.” At a time when so many Americans struggle to maintain or return to a healthy weight, empowering consumers to make healthier choices with responsible labeling is important. Despite DGA advice to
consume a wide variety of whole fruits and vegetables, Americans in every age group and across socioeconomic lines consistently fail to consume the amount of fruit and vegetables recommended. Accordingly, the FDA plays a critical role in changing the course of the nation’s health and nutrition crisis. We thank the agency for taking a bold approach and stand ready and willing to assist as the Nutrition Innovation Strategy (NIS) moves forward. 


TK: Well said by United Fresh. The broader food industry should stop stealing the health halo of fruits and vegetables with worthless health claims.


Submitted by R Henry on Tue, 10/16/2018 - 10:54

So, UnitedFresh, with offices in Washington DC, seeks resolution of such issues via FDA regulation. What a surprise!

Thing is, what we eat is determined by cultural elements--regulatory issues are very much in the background. As such, FDA can say anything....and will be largely ignored when we have hunger pangs....and need something to eat.

More governmental intervention is entirely pointless here UnitedFresh...wasting your time and money.

Submitted by John Pandol on Tue, 10/16/2018 - 15:18

One of the simplistic mantras is "plant based good, animal based bad". I see the move toward plant based foods as a THREAT to produce, in that highly processed "plant based" foods will be largely molecularly restructured cereal grains with some plant parts from fruits or vegetables simply for 'health halo' effect. What we eat is determined by culture....and our culture no longer cooks. The kitchen is the new sewing room.