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FDA Labeling Changes Could Come at a Cost for Food Processors

Front-of-pack labeling, reduced sodium and sugar levels, and enforced ingredient traceability are on the horizon for food manufacturers. Here’s what processors can expect next.

FDA FOP Labeling Examples
Some examples of front-of-pack labeling being proposed by the FDA, which focus on a traffic-light format with three key ingredients highlighted.
Michael Costa

Certain segments of the food and beverage manufacturing industry—like snack foods—have been blamed in recent years by health and nutrition advocacy groups and government entities for being at the root of the country’s obesity epidemic, along with other maladies like diabetes, high blood pressure, heart disease, and more.

One solution proposed by these groups is to enact a variety of changes within the food and beverage manufacturing industry, including simplified labeling, lowering levels of sodium and sugar, and enforcing ingredient traceability for allergens. All of these scenarios could put the financial onus on the manufacturer to execute within their operations.   

Martin Hahn, partner at Hogan Lovells and SNAC International general counsel, recently discussed where these topics currently stand at SNX in Dallas for an audience of snack manufacturers. Here’s a roundup of what Hahn says processors can anticipate from these proposed initiatives.

Front-of-pack nutrition labeling

In 2022, the White House National Strategy on Hunger, Nutrition, and Health was released, with the goal of ending hunger in the U.S., along with encouraging healthy eating and physical exercise in the population by 2030, which in turn, could reduce diet-related maladies like obesity, diabetes, high blood pressure, and more. Hahn says the underlying message of this strategy is that the bulk of the change needs to come from the food industry through labeling changes and reduced sodium and sugar, rather than focusing more on changing people’s eating habits.

“I felt like if you’re in the food industry then everything is your fault,” says Hahn. “When you look at what was coming out of this program, it was all about what the FDA had to do and what the [food and beverage] industry should be doing to try to take more responsibility for the chronic disease that we have in this country, and I just inherently think that’s unfair.”


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Within this government strategy, the FDA has been tasked to focus on standardized front-of-pack (FOP) nutrition labeling, and simplifying it to a trio of ingredients—saturated fat, sodium, and sugar—while using graphics similar to a traffic light, where red would mean high levels, green would mean low levels, and yellow would mean average levels. This scheme is still in the market research stages to see if it will resonate with consumers, and has not been mandated to the food manufacturing industry yet.

“What’s really surprising is this format excludes calories,” Hahn says. “I’m not a nutritionist, but I’m pretty certain calories are a key component [for diet]. I would consider calories to be the single most important factor consumers need to know if they’re trying to maintain a calorie static lifestyle.”

According to the FDA, FOP nutrition labeling would complement the traditional Nutrition Facts label rather than replace it, with FOP labeling helping consumers with lower nutrition knowledge to quickly and easily identify foods that can help them build a healthy eating pattern.

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Back to Basics: Understanding Conveyors for Food Processing