Should there be a voluntary symbol for “healthy food”? Kroger chimes in
Posted on regulations.gov, here is a comment from Kroger to the FDA on the topic of a voluntary symbol depicting the nutrient content claim ‘‘Healthy’’ on packaged foods.
Comments are due on the topic July 6.
I find it interesting that Kroger advocates to the FDA to ensure that bulk fresh produce without a label should still have the “healthy” symbol prominently displayed.
Kroger writes: "While it may seem obvious that fruits and vegetables would be a healthy choice, patients have asked our dietitians if bananas or berries are healthy, assuming that some produce is higher in sugar than others and therefore not a healthful choice,” Kroger said in the comment.
The full comment from Kroger:
As America’s largest traditional retail grocer, simplifying health information to help people live healthier lives is a top priority. Kroger supports the proposed quantitative research to identify a relevant, effective symbol to depict the “healthy” nutrient content claim for Americans. The use of online surveys alleviates participant and administrative burden while expanding the research reach. The information collected during these studies will have practical utility for effectively helping customers choose healthier options.
Defining “healthy” and conveying healthy options to the public is no simple task. It can be challenging to distill the many attributes in a food or beverage product into a single consumer-facing depiction. We also recognize how the many different publicly available nutrition scoring systems designed to make healthful choices easy may have different thresholds of what’s considered “healthy”, which may sow consumer confusion. The FDA’s important work will help private and public industry to align around a single definition of healthy and improve consumer understanding of better-for-you choices.
While we support the proposed research, we have a few suggestions to potentially improve the proposed research and outcomes:
1) Our team of dietitians stress the importance of incremental change. In our own nutrition scoring system, OptUP, customers are provided the opportunity to choose a similar better-for-you product with a higher OptUP rating. We feel strongly that small improvements in eating patterns over time are the key to sustainable change. While we see the value in an overarching “healthy” symbol, we also see challenges around a black and white mindset that may discourage better-for-you items that don’t meet the proposed definition of healthy but still contain healthful attributes. There is potential for consumer confusion around these grey items. Take for example, if a breakfast cereal with 10 g of added sugar but 5 g of fiber per serving does not receive a “healthy” symbol. While the 2020-2025 Dietary Guidelines for Americans recommends limiting added sugar, the Guidelines also recommend fiber consumption. Our suggestion: Consider having participants compare items with a “healthy” symbol and an item with healthful attributes that may not meet the FDA proposed definition of healthy to evaluate any potential unintended consequences of discouraging items that provide important nutrients.
2) We’d like to reiterate the potential challenges of a “healthy” symbol. Our dietitians know that what’s considered “healthy” is variable and depends on the individual, including personal health history. What’s healthy for some may not be healthy for others. To ensure that the FDA creates inclusive and positive guidance for consumers, we suggest testing other potential symbol terms (e.g., “nourishing”, “nutrient-dense”) in Study 1 of the proposed research.
3) Ensure that fresh produce without a label will have the “healthy” symbol prominently displayed. While it may seem obvious that fruits and vegetables would be a healthy choice, patients have asked our dietitians if bananas or berries are healthy, assuming that some produce is higher in sugar than others and therefore not a healthful choice. Lack of a “healthy” symbol may confirm misconceptions. We do not think it’s necessary to place “healthy” stickers on individual apples, for instance, but some denotation in the produce section is needed. Perhaps Study 1 could include probing questions about the use of the “healthy” symbol regarding produce, and where the placement of that symbol would be best be utilized by the consumer.
4) The proposed symbols 14a, 14b, and 15a, 15b resemble the USDA Organic label with the rounded boundary, half-colored center, agency name on top, and qualifier on bottom. We caution using these proposed symbols in the final rule to prevent the equation of “organic” with “healthy” or cause consumer confusion among symbols.
We appreciate the FDA’s continued work in this space to simplify healthful eating and help consumers live healthier lives.
Kroger Health
555 Race Street, Cincinnati, OH 45202
