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Some People Have Strong Opinions on How We Should Define ‘Healthy’

The Food and Drug Administration opened the question up for comment. It received more than 1,000 replies.
Healthy, or not? (Photo: Wikimedia Commons)

Healthy, or not? (Photo: Wikimedia Commons)

What does it mean for a food to be “healthy”? The Food and Drug Administration has been considering this question for several months now, soliciting comments from the public about what requirements must be met for a food to be labeled “healthy” on packaging. Comments finally closed last week, after the FDA received more than 1,000 notes from consumers’ groups, public-health agencies, food companies, and normal citizens. It seems Americans have a lot to say about healthy eating.

It’s been nearly 23 years since the FDA published regulations about what foods may be considered “healthy”; the general consensus among nutritionists at that point was that Americans should try to eat less fat, cholesterol, and sodium, and eat more vitamins and fiber. Since then, nutrition science has shifted its focus away from overall fat amounts to concentrate more on specific types of fat. Scientists have also gathered more evidence that eating too much sugar may lead to diabetes or heart disease, which wasn’t as much of a worry in the ’90s.

These revelations left the FDA badly in need of an update, as two FDA officials wrote in a blog post. (A disagreement with the energy bar maker KIND also played a role prompting the FDA’s re-evaluation, Fortune reports.)

Pacific Standard looked through the FDA docket and news reporting for the best comments around this hot topic. We should warn you that we in no way conducted a systematic search of the FDA’s materials. Instead, we sought interesting themes that we hope can help frame your thinking around healthy eating.

1. Look at It Holistically

Several groups urged the FDA to think about diets holistically, and not to allow companies to label their products “healthy” just because they hit targets for one or two nutrients.

From the New York State Department of Health:

We join with other petitioners and interested stakeholders in requesting that FDA amend the regulation defining the nutrient content claim ‘healthy’, to emphasize whole foods and dietary patterns rather than specific nutrients.

Here’s the American Society for Nutrition, a group for nutrition researchers:

ASN … recommends that the saturated fat, fat and cholesterol not be considered in isolation with regard to use of the term healthy. It is important to look at the total range of nutrients contributed by a food.

The Center for Science in the Public Interest, a consumers’ group that advocates for healthful food regulation and marketing, asks the FDA to emphasize certain food types…

FDA should define ‘healthy’ to include only fruits, vegetables, whole grains, low-fat or non-fat dairy, lean poultry, fish, legumes, and nuts and seeds.

… but it also has some pretty specific recommendations for what nutrient levels foods should have to meet in order to be labeled “healthy”—supporting the FDA’s current saturated fat and cholesterol limits, for example. At 26 pages, the Center for Science in the Public Interest’s comment is one of the longest we encountered.

2. Look at It Specifically … and Include Me

At the other end of the spectrum, associations representing various food companies had quite specific complaints about the FDA’s current rules and proposals others have made. FoodNavigator-USA complied some of these opinions in a recent story. United Egg Producers and the California Walnut Commission object to the saturated fat limits, for example. (The Center for Science in the Public Interest does suggest nuts and whole grains with no other added ingredients should be considered “healthy,” even if they don’t meet the FDA’s recommended nutrition limits.) The Academy of Nutrition and Dietetics and the Center for Science in the Public Interest both think that foods with vitamins or fiber added to them shouldn’t be considered any healthier than their unfortified counterparts, but the American Bakers Association disagrees.

3. What Even Is Healthy?

Should anything be called healthy? Some question whether the word should be used on food packaging at all. New York University nutrition professor Marion Nestle argued to NPR that letting companies stamp “healthy” on their packages leads to misleading marketing. The Academy of Nutrition and Dietetics is “concerned that the term ‘healthy’ has the potential to cause consumer confusion because it seems to imply that a single food should meet all dietary needs” and refused to offer any recommended definition to the FDA, as FoodNavigator-USA reports. The American Society for Nutrition took a gentler approach, suggesting that maybe the loaded word should be applied to “characteristics of a food” rather than foods overall.

The FDA argues, however, that getting “healthy” on labels is important. “The typical consumer makes a purchase decision in three to five seconds. They don’t have a lot of time,” Douglas Balentine, director of the FDA’s Office of Nutrition and Food Labeling, told NPR. “We want to give consumers the best tools and information about the foods they choose.”

4. What About Grammar?

One anonymous commenter noted that, technically speaking, the word “healthy” should only apply to living organisms, not to foods. “Foods are not ‘healthy,’” they write, although “eating certain foods can aid a person to be healthy.”

“Semantics and grammar in our civilization have become miserably forgotten,” they add.