Can the FDA’s new rules help people eat healthier?

With major changes to the limits on fat, as well as new limits on sugar, we can expect quite a lot of reshuffling of what gets advertised as healthy in the coming years. That might help settle some consumer confusion about products that use the label while being high in added sugars. At the same time, there’s a broader question of how useful a label that asserts individual foods as “healthy” can be when ultraprocessed food (UPF) manufacturers are better than ever at checking the boxes to meet nutrition requirements.

Why “healthy” needed an update

Under the old rules, so-called healthy foods had to be low in fat, cholesterol and sodium, and also contain at least 10 percent of the recommended daily amount of Vitamin A, Vitamin C, calcium, iron, protein or fiber in order to use the label on packaging.

Those standards reflected both the state of nutrition science and the offerings of the food industry in 1994: Fat, especially saturated fat, had been identified as a major contributor to heart disease, as had dietary cholesterol. Fat, being more calorie-dense per gram than sugar and protein, was also identified as the main problem when it came to rising rates of obesity, diabetes and other metabolic diseases. As a result, the 1990 Dietary Guidelines that the rules were based on (and the accompanying food pyramid) recommended 6-11 servings of grain a day, and didn’t set specific guidelines for sugar intake beyond general advice for moderation.

In the 30 years since those guidelines, nutrition science has evolved considerably. Fat has had something of a redemption arc, with researchers affirming that fats should be part of a healthy diet, particularly heart-healthy unsaturated fats and omega-3s that are found in fish, nuts and seeds. And while most nutrition experts still recommend limiting saturated fat intake overall, it isn’t quite as demonized for its role in disease as it was in the past. Our understanding of cholesterol has shifted too, with recent research suggesting that consuming cholesterol doesn’t directly increase blood cholesterol as previously assumed. As a result, cholesterol recommendations today are largely in place simply because most foods that are high in cholesterol are also high in saturated fat, with the notable exception of eggs.

Messaging on carbohydrates has also gotten more complex, especially when it comes to added sugars. Although grains are still broadly recommended, they don’t dominate MyPlate (the simplified graphic system for teaching the Dietary Guidelines) in the same way that they did its predecessor, the food pyramid. The 2020 Dietary Guidelines, which form the basis for the new healthy rules, repeatedly emphasize that whole grains should make up half of our carbohydrate intake, a big change from the suggestion to include some whole grains in 1990. But perhaps the biggest change has come with recommendations regarding added sugars, which the 2020 iteration recommends limiting to less than 10 percent of daily calories.

That’s largely a response to the sugar-laden food environment (and accompanying rise in obesity and metabolic disease) ushered in by the fat-free craze, something epitomized by the original 1994 rules around the use of “healthy” on food packaging; wrappers, bags and containers often trumpeted claims of low- or no-fat, but were conspicuously silent on sugar content. For many years, heavily sweetened packaged foods like low-fat yogurt, cereals and more have carried the healthy label. As refined sugar’s role in our dietary woes has become clearer, the fact that so many foods labeled as healthy have so much of it has led to ample confusion among shoppers and criticism from experts.

Food companies also lobbied the agency to update its guidelines for the healthy label, most notably KIND, which petitioned the FDA for permission to call its nut-based snack bars healthy. The company had received a warning from the agency in 2015 to stop using the word “healthy” on its packaging because the bars contained too much fat — despite that fat coming from nuts, an ingredient that nearly everyone agreed should qualify. After petitioning the agency for a change, the FDA announced in 2016 that KIND would be allowed to use “healthy” on its packaging, provided that the language reflected KIND’s corporate philosophy rather than an actual health claim. They also indicated they would be similarly lenient with other products that might overstep the fat threshold with healthful unsaturated fats.

The new guidelines

The new guidelines maintain some of the structure of the old system by imposing caps on certain nutrients, though the list is a little different. There are still limits on sodium, but the new rules only stipulate a limit for saturated fat rather than overall fat. That saturated fat limit also specifically excludes nuts, seeds, seafood and soy, in recognition of the fact that these nutrient-dense ingredients should be promoted in a healthy diet.

There are also new limits on added sugars, with a general maximum of 5 percent of the daily allowance per serving. That translates to a maximum of 5 grams of added sugar in grain products, and lower limits for fruit, dairy and other food groups. Interestingly, dried cranberries and tart cherries, which are unpalatably sour to most people without some added sugar, will get an exemption, provided they aren’t sweetened beyond the natural sugar levels found in other dried fruits like raisins.

These limits are important changes that better reflect the excesses in most people’s diets. But the more foundational change comes with what foods have to contain to be considered healthy in the first place. Rather than setting targets for desirable nutrients, the new rules work off of “food group equivalents,” with a food needing to provide the equivalent of one serving of a vegetable, fruit, protein food, carbohydrate or oil. Single ingredients, like eggs, that represent one of the major food groups will automatically qualify for the label provided they don’t exceed the limits on saturated fat (foods with any additives, including sugar or sodium, wouldn’t be considered a single ingredient anyway) — marking a big change that will allow most whole, fresh foods to use the healthy label.

So what foods are in and out? With the new fat rules, nuts and nut-based products (like those KIND bars) will now count as healthy, along with avocados, fattier fish (such as salmon), game meat, eggs and heart-healthy oils like olive oil. Outside of skim and low-fat milk, unsweetened low-fat yogurt, and some low-fat cheeses, most dairy products won’t qualify. Sweetened yogurts — which proliferated in the last few decades thanks to the notion that they were a healthy, low-fat snack for kids — are also out.

What’s missing from the new rules

The new guidelines certainly better reflect our current understanding of health and nutrition than the ones they’re replacing, especially when it comes to the importance of healthy fats and whole foods, as well as limiting added sugars. But perhaps the most important shift in nutrition thinking that’s occurred in the last few decades — thinking about health as part of a whole diet or pattern of eating rather than categorizing individual foods as healthy or unhealthy — is ultimately still something the new rules don’t capture. Basing the new system on food groups is a nod to the whole-diet approach, but assigning a healthy label to individual products still reinforces that flawed binary way of thinking.

That good-bad dichotomy ultimately benefits food manufacturers, who like the idea that we should think of foods simply as the sum of their nutrients — an approach that food policy researcher Dr. Gyorgy Scrinis coined as “nutritionism.” Modern food-processing techniques make it easier than ever to give processed foods a healthy veneer. The ability to list isolated proteins, starches and fibers on a nutrition label make it easy to bump up the quantity of desirable macronutrients, while additives such as flavorings, zero-calorie sweeteners and emulsifiers allow manufacturers to cut down on sodium, sugar and fat without sacrificing flavor or texture. Under the logic of nutritionism, for example, a handful of high-fiber superfruit gummies might seem like the healthier, more nutrient-dense option than a handful of blueberries.

There’s obviously room for nuance in the discussion of UPFs, which aren’t all created equal: While the phrase immediately conjures images of high-calorie snack foods and sodas, it also covers a number of “health foods,” from shelf-stable whole wheat bread to the protein powders and electrolyte gels guzzled by performance athletes. Ironically, sports nutrition is almost entirely dominated by UPFs, thanks to pervasive nutritionism that reduces food to individual macronutrient targets best met through isolated, usually powdered, forms without the “extra calories” or bulk that comes from eating them in everyday foods.

That flies in the face of perhaps the most universal consensus in nutrition science — that diets should be composed mostly of whole and minimally processed foods. So while some processed foods might be healthy on paper — or even qualify for the FDA’s label — diets heavy in “nutritionally optimized” processed foods don’t confer the same benefits as those that opt mainly for whole foods instead (something researchers are piecing together as they unravel how even “healthy” processed foods can negatively impact the human microbiome).

In recent years, even conservative, industry-influenced resources like the USDA’s dietary guidelines have shifted away from calling individual foods healthy or unhealthy and embraced a whole-diet approach. That’s tangible in the move from the old food pyramid, which hierarchically sorted foods according to healthfulness, to MyPlate, which approaches meals and diets much more holistically. In that context, there’s a question of whether or not the new FDA rules about the healthy label for individual foods — despite being based in the dietary guidelines — are actually congruent with the whole-diet approach otherwise preferred by public health bodies.

It’s hard to deny the need for some guidelines on what companies can market as healthy, and the new rules are certainly better than the old at filtering out foods that are high in empty calories. But if nutritionism can muddy the waters between whole foods and more processed options, looking at processing might be a useful dimension to consider adding to future updates.The FDA’s first proposal for a warning label on processed food doesn’t actually solve this problem, since it only highlights fat, sugar and sodium rather than the degree of processing.

Defining what makes a food processed (or ultraprocessed) is contentious, with the current NOVA system — the most widely used schema for classifying processed foods — criticized by some as too subjective and inconsistent to be nutritionally useful. Meanwhile, industry-led attempts to define standards for processing have been met with firm opposition from nutrition researchers and public health advocates, who warn that they further distort already fuzzy messaging about food processing. However, it’s increasingly clear that our current approach to food labeling isn’t doing enough to help people identify UPFs and tilt them toward less-processed options.