How will the new labeling rules affect you?

ABC News reported the FDA will propose a shift in how food and beverage companies calculate and list their nutritional analysis.[1]

"Our guiding principle here is very simple, that you as a parent and a consumer should be able to walk into your local grocery store, pick up an item off the shelf and be able to tell whether it's good for your family," said first lady Michelle Obama, who was to join the Food and Drug Administration in announcing the proposed changes Thursday at the White House.

What Will Change?

Serving Size:  Change from arbitrary serving sizes to a more realistic calculation on what consumers actually eat.  (Ex:  a 12 oz soda would no longer be calculated with an 8 oz serving size, but the 12 oz). Calories:  The new serving size will definitely impact the calorie calculation, but the result will also be in a mandated bigger, bolder type. Added Sugars:  Along with calories, the FDA wants greater visibility to sugars that are added to the product.  This will also be impacted by the revised serving size

Images from FDA site:  http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm387418.htm

When will it change?

The change is not expected in the immediate future, but a rollout over the next few years. 

According to ABC News, “The FDA will take comments on the proposal for 90 days, and a final rule could take another year. Once it's final, the agency has proposed giving industry two years to comply.”

What can I do now?

Accurately assess all ingredients.

The ingredients are your starting point for the formulations.  Before you begin analyzing what the new labeling will look like, you need to make sure that you have accurately captured all of the current ingredient’s nutritional information.  This is especially important for bought materials.  If you do not already have an automatic synchronization with vendor specifications, you should find a way to integrate the data.

Evaluate current formulations.

Once you have your ingredient attributes accurately defined, you should move on to analyzing your existing formulations.  You must include all formulation ingredients, including the proprietary formula-within-a-formula and as stated above, bought ingredients.  This is known as a linear explosion, and should be available in an effective Product Lifecycle Management Formulation tool. 

You should also be able to easily change the serving size in your formulation tools to reflect what a realistic size may be.  Once this has been completed, you should be able to have a better understanding of what the new label will look like.

Analyze current nutritional claims.

The reconfigured serving size may directly impact your current product claims (ex:  low calorie, low energy, low sugar, etc.).  You must evaluate the revised serving size calculations against the government-defined regulations for substantiating these type of claims.  Some regulatory tools in PLM software feature this type of analysis and also generate the required documentation.

Coordinate with marketing.

Your marketing department will need to be kept aware of the potential changes with the product labeling and subsequent packaging.  They may also need to redefine product requirements to meet the core demographic trends.

[1] http://abcnews.go.com/Health/wireStory/food-labels-highlight-calories-sugar-22692613

Read More