Nutrition Facts Label clarity: Guidance for dual-column labeling and serving sizes unveiled by FDA

02 Jan 2020 --- In response to industry confusion, the US Food and Drug Administration (FDA) has issued final guidance on the requirements for dual-column labeling and serving sizes on the Nutrition Facts Label. The new guidance addresses the serving sizes of foods, including single-serving foods and other foods that can reasonably be consumed at one eating occasion and require dual-column labeling. Compliance with the updated Nutrition Facts labeling regulations was required by yesterday, January 1, 2020, for manufacturers with US$10 million or more in annual food sales, while manufacturers with less than US$10 million in annual food sales still have an additional year to comply.

“In the new guidance, we are helping answer some of the questions most commonly asked by industry about dual column label and serving size issues, including when dual-column labeling is required, the definition of a single-serving container, how to determine the number of servings in a food product and how these labels should be formatted for some products that have limited space for nutrition labeling,” explains Dr. Claudine Kavanaugh, Director of the Office of Nutrition and Food Labeling in the FDA’s Center for Food Safety and Applied Nutrition.

The FDA previously postponed enforcement actions after manufacturers and industry groups requested more time to comply with the new label requirements. During the first six months following yesterday’s compliance date, the FDA will work with manufacturers to help them meet the new Nutrition Facts label requirements. Moreover, it will not focus on enforcement actions regarding these requirements during that time.

With the introduction of the new Nutrition Facts label, a variation that consumers are seeing is the dual column label for some foods that can reasonably be consumed in one meal or snack.“With the introduction of the new Nutrition Facts label, a variation that consumers are seeing is the dual column label for some foods that can reasonably be consumed in one meal or snack. This label has two columns, one for listing the nutritional facts related to a single serving and one listing the nutritional facts for the contents of the entire package,” Dr. Kavanaugh says.

The guidance includes clarifications such as:

• Providing additional background information in response to a question regarding reference amounts customarily consumed (RACCs) for non-juice beverages for infants and young children.
• Modifying for clarity a question and response on whether the Nutrition Facts label for products sold in small packages must list all nutrients that are contained in insignificant amounts.
• Modifying the response to a question regarding the placement of the Nutrition Facts and Supplement Facts labels to clarify that the Nutrition Facts or Supplement Facts label should not be placed on the bottom of packages (such as the bottom of boxes, cans and bottles) unless they are visible during normal retail display and consumer handling.

“The new Nutrition Facts label has updated serving sizes for many foods. We know that US consumers are eating differently, and the amount of calories and nutrients on the label is required to reflect what people actually eat and drink – not a recommendation of what to eat or drink. The new label, including this dual column layout, will drive consumers’ attention to the calories and Percent Daily Value of nutrients that they are actually consuming,” she adds.

Importance of labeling for nutrition
The revisions are intended to reflect the changes in science and dietary habits that have occurred since the nutrition labeling regulations were first established in 1999.

Last September, 13 trade associations appealed to the FDA to provide the necessary flexibility in its enforcement of the new nutrition labeling rules. A letter indicated that extra time to implement the new changes is needed due to the magnitude of the task of revising all labels, the difficulty of predicting label inventory levels and the high cost and environmental impact of disposing of existing label inventory. Moreover, the continued use of existing labels for a short period following the compliance date would not present a risk of misleading consumers, states the letter.

Outside of the US, the traffic light resembling the Nutri-Score labeling system has been called the most effective style of front-of-pack labeling (FoPL) to help consumers rank products according to their nutritional quality. Spanish supermarket chain Eroski became the first European store to introduce the Nutri-Score system, doing so on a handful of its own-brand products in January 2019. France and Belgium also use the labeling system voluntarily in an attempt to uniform the nutritional labeling system in Europe. 

Science-backed facts found on food labels are of paramount importance to ensure consumers can make informed, healthy purchasing decisions. The FDA, for example, has previously implemented labeling differentiation between “nutrition” and “supplement” facts to ensure responsible supplement manufacturers and suppliers will promote product transparency.

Edited by Kristiana Lalou