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Food Labels: What They Reveal and Conceal
American consumers are paying increased attention to food labels in order to make healthier choices for themselves and their families, but, unfortunately, these labels are often misleading. Federal laws regulating food labels are complicated and can be difficult to understand. Moreover, the mainstream food industries frequently attempt to manipulate the wording on labels to hide any potentially negative information.
For example, in a 2012 incident that raised public outcry, the dairy industry petitioned the Food and Drug Administration (FDA) to change the standards of identity for milk and 17 other dairy products.[1] If this petition is granted, the amended standards would still require that such sweeteners be itemized in the product’s ingredient list, but their presence would no longer need to be revealed on the front of the package. Sweetened, flavored milk, for example, would not have to be described as reduced calorie if it contained artificial sweeteners. This could potentially mislead consumers and weaken the protection provided by front panel regulations.
Some of the more significant federal guidelines regulating food labels, along with common manufacturers’ label claims, are discussed below. Knowing what to look for and how to interpret information on food labels can help you to shop wisely.
Claims on the front of the package
The FDA stipulates that, for all packaged foods, the front panel of the label must declare the food’s common name. Some basic foods, such as milk, tomato paste, and chicken broth, have standards of identity that must be met in order for the common name to be used. Milk, for instance, is required to contain a percentage of milk fat that falls within a specified range. Otherwise, it must be given a descriptive name such as skim milk or nonfat milk.
For non-standardized foods, names must describe the food in plain language, such as reduced-fat sour cream or sugar-free cookies. These names reveal important facts about the product. The phrase reduced-fat, for example, indicates that the product has been intentionally altered to lower the fat content, which may mean that synthetic additives and fat substitutes (such as olestra) were added. Reduced-calorie and sugar-free products have been similarly altered, often by replacing sugar with artificial sweeteners. Names like these can make it easier for health-conscious consumers to avoid potentially harmful ingredients.
Label claims that frozen meatballs “contain 100% real beef” or that chewy fruit cookies are “made with real fruit,” on the other hand, are not as straightforward as they appear. Such claims are allowed by the FDA as long as the stated item is actually one of the product’s ingredients.[2] However, they are often misleading to consumers. In addition to beef, the meatballs may also contain binders and extenders, and the “real fruit” cookies may also contain sugar, corn syrup, artificial sweeteners, flavoring, or added colors.
Claims that a product is “made with whole wheat” or has “two grams of whole grains” also should be interpreted with caution, as such items may include white flour among their ingredients. Whole wheat bread – like whole wheat rolls, buns, and macaroni – is a standardized product that must be made using only whole wheat flours.[3] However, this principle does not apply to products for which the FDA does not prescribe standards of identity, such as breakfast cereals, bagels, muffins, or pizza crusts. These products may bear names based upon a “characterizing” ingredient,[2] which could be whole wheat or oat bran, even if white flour is the first item on the ingredient list.[4]
Some companies have recently begun to place what might appear to be the ingredient list on the front of the package. For instance, a box of whole wheat crackers might say “made with organic whole wheat, olive oil, filtered water, and sea salt” on the front, but a look at the full ingredient list could reveal that the product also contains artificial preservatives. The official ingredient list is usually placed below the nutrition facts on an information panel. Anything else that appears to be a list of ingredients may be incomplete.
Allergy information may also appear on the front panel, but this is not required by law. The FDA mandates only that foods containing common allergens (milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, and soy) must clearly indicate their presence either in the ingredient list or in the space after or adjacent to it.[5] Although many manufacturers use the familiar warning “Contains X” after the ingredient list, those with allergies should always carefully check the list itself.
Although the presence of non-wheat gluten does not have to be disclosed, a new rule passed by the FDA has standardized the use of the term gluten free.[6] For a product to be considered gluten free, it cannot contain whole grains or flours from wheat, rye, barley, or crossbreeds (such as triticale). A small amount of gluten may be present due to cross-contamination from shared manufacturing equipment or from ingredients that have been refined to remove their gluten. However, gluten-free products are permitted to contain no more than 20 parts per million (ppm) of gluten. All products that claim to be gluten free must comply with this regulation by August 5, 2014.
Labeling for unpackaged food
Most food labeling regulations apply to packaged food, but there are also labeling requirements and voluntary guidelines for unpackaged products. Foods sold in bulk bins, such as grains, flours, beans, and nuts, must have nutrition information available at point of sale – for example, listed on the container itself or on a card nearby.[7] Since 2012, major cuts of raw, single-ingredient meat and poultry, as well as ground meat and poultry, are required by the U.S. Department of Agriculture (USDA) to have their nutrition information stated, with certain exceptions.[8]
Providing nutrition information for raw fruits, vegetables, and fish sold by the pound is voluntary, but the FDA urges food retailers to do so, and many major grocers comply.[9] Sometimes, the nutrition information is printed on posters or brochures, available in areas of the store where these products are displayed.
This information is also available online in the USDA National Nutrient Database.[10] However, consumers should be aware that fresh fruits and vegetables may contain additives (such as wax on apples or Citrus Red No. 2 on oranges) that are not listed at point of sale. To find out if a particular fresh fruit or vegetable has been coated with something, ask to see the shipping box for the item, which is required to display this information.[11]
Organic and natural products
To be labeled USDA organic, a product must meet the requirements set forth by the USDA’s National Organic Program. The USDA defines an organic food as one that “has been produced through approved methods that integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity.”[12] In practice, many organic farms and products fall short of this qualitative ideal, but this does not mean the organic label is meaningless. Organic products must meet several objective criteria. The most well known is that organic crops must be grown without synthetic fertilizers, prohibited pesticides, or sewage sludge. In addition, they cannot be grown from genetically modified seed or irradiated to increase shelf life.
While fresh fruits and vegetables (as well as grains, nuts, seeds, etc.) are simple to classify as either organic or not, products with multiple ingredients can be partially organic. These products can be labeled 100% organic if all ingredients (except for water and salt) are certified as such. Organic products must be composed of at least 95 percent organic ingredients, as determined by weight, and products “made with organic ingredients” must be at least 70 percent organic.[13] If a product has less than 70 percent organic ingredients, individual ingredients may be declared organic in the ingredient list, with the total percentage of organic ingredients stated on the information panel, near the nutrition information.[14]
Meat and poultry may be labeled organic if the animals were allowed access to pasture during the grazing season, were fed 100 percent organic feed, and were not given hormones or antibiotics.[15] The term natural may also be used for meat and poultry, but it has a very different meaning. USDA guidelines allow products to be labeled natural if they are minimally processed and contain no artificial ingredients, such as colors, flavors, or preservatives.[12] Natural is a relatively low standard; feedlot cattle can qualify, as can chickens that never see daylight. Certified natural beef refers to beef endorsed by independent organizations (not the USDA) that set their own standards, which usually prevent the use of antibiotics but are much less stringent than organic standards.[16]
USDA terms for poultry include free range and cage free, neither of which are high standards. Cage free means that the animals can move about in a room or building; it does not mean they have access to the outdoors. Free range means that they have access to the outdoors, but the outdoor area does not have to be large or even grassy.[12] Pasture raised is the ideal standard for poultry (as well as meat), although use of this term is not regulated.
Organic certification is not handled directly by the USDA, which instead accredits independent certifiers and periodically audits them. While all certifiers must meet the same criteria in theory, not all represent the same level of quality. California Certified Organic Farmers (CCOF) and Oregon Tilth are examples of certifiers that have good reputations. Certifiers can be state agencies, non-profits, or for-profit corporations, and identifying the status of a certifier is a good first step in assessing it. Another strategy is to see which certifiers are used by honest companies that you know and trust.
Some small growers and manufacturers produce foods that would meet organic standards – and may use the term organically grown on their labels – but choose not to get certified because they find the record-keeping requirements and the cost of the required annual audits too burdensome. Other growers opt out because they object to the system of organic certification on the grounds of ethics or sustainability.[17] One such complaint is that organic farms are allowed to use chemical-laden feedlot manure on their fields. Moreover, certain healthful foods, such as sea salt and wild salmon, cannot be certified organic because they are neither grown nor raised.
Ingredient lists
In general, the FDA requires that all ingredients be listed on food labels by their usual or common names. Reading the ingredient list is truly the best way to learn about the product. That said, there are regulations that allow certain ingredients to be presented in ways that may be deceptive or misleading.
For example, some ingredients may be given names that fail to fully describe them, and thus they may be more heavily processed than most consumers realize. Milk can refer to fresh milk, concentrated milk, dry milk powder, or reconstituted milk made with added water.[18] This is true not only for foods that contain milk as an ingredient but also for milk sold to drink. Buttermilk, skim milk, whey, and cream can also refer to products that have been dried, concentrated, or reconstituted. Eggs can refer to liquid, dried, or frozen eggs; the same is true for egg yolks and egg whites.
Confusion can also occur from the use of less-familiar names for ordinary products. For example, many products marketed as “natural” foods use the terms cane sugar or beet sugar, when the ingredient in question is simply refined white sugar. In fact, the FDA stipulates that cane sugar, sugar, and sucrose are interchangeable terms.[19] Similarly, white flour is often listed as wheat flour or unbleached white flour. Although not untrue, such descriptions serve to draw consumer attention away from the fact that the ingredient is ordinary white flour, a highly refined product. All wheat flour is unbleached unless otherwise specified or unless the bleaching additive is included in parentheses as an additional ingredient.[20]
Historically, the ingredient that has been most frequently disguised on food labels is undoubtedly monosodium glutamate (MSG). All protein hydrolysates, or hydrolyzed proteins (whether from casein, soy, beef, or other sources), are simply forms of MSG. Textured vegetable protein and yeast extract also contain it. Previously, these ingredients could be concealed by listing them as natural flavor or flavoring,[21] but today the FDA requires that virtually all protein hydrolysates be listed individually. The exception involves those present in meat products, which are regulated by the USDA rather than the FDA. Any meat or poultry products that contain flavoring, flavor, or natural flavor may contain protein hydrolysates.[22]
Some ingredients (most notably, oils) can be listed even if they are not always present in the product.[18] When a manufacturer includes a phrase such as “cottonseed, soybean, and/or canola oil,” the cheapest available oil is usually being used. These oils are highly refined and, quite likely, genetically-engineered.
There is currently no requirement that food containing genetically modified organisms (GMOs) display that fact anywhere on the label. However, provisions in the Food, Drug, and Cosmetic Act make it possible to identify certain genetically modified ingredients.[23,24] When a food of any sort differs from the traditional version in nutritional content, its name must reflect the altered quality.
Therefore, soybean oil that has been genetically engineered to increase the oleic acid (an omega-9 fatty acid) content must be listed as “high oleic acid soybean oil.”[25] Any ingredients that are listed as being high or low in something have been intentionally altered, and may be genetically-modified.
Food additives generally appear at the end of the ingredient list, which is organized in descending order by weight. Often, the last several ingredients are preceded by a statement such as “contains less than 2% of the following.” However, taken together, these ingredients may constitute a much larger percentage. Although most additives must be named on the ingredient list, incidental or indirect additives that are present in trace amounts, often as part of another ingredient, are exempt. These are most likely to be found in heavily processed or prepared foods such as soups, sauces, seasoning packets, breaded chicken or fish, and frozen entrées. You can often use the length of the ingredient list as a tool to quickly estimate how heavily processed a food may be, since more ingredients and more additives tend to indicate more processing.
Accuracy of nutrition information
The Nutrition Facts Label gives a summary of the estimated nutrient levels in a food, based on the specified serving size. Manufacturers originally used their own discretion in setting serving sizes, which often resulted in wildly inappropriate amounts. The Nutrition Labeling and Education Act of 1990 (NLEA) put a stop to highly variable serving sizes by setting standards for all common food products. The NLEA specified reference amounts that supposedly represent the amount “customarily consumed per eating occasion,”[26] but many of these have come into question, and the FDA is now considering revisions.
The NLEA not only made nutrition information mandatory but also shifted the emphasis from necessary nutrients to allegedly unhealthy ones, such as fat and sodium.[27] Unfortunately, the nutrition facts do not distinguish between naturally occurring sodium and refined salt, or between natural fats and refined oils. Thus, a quick glance at the label may suggest that a heavily processed frozen dinner is more nutritious than a salad with cold-pressed, extra-virgin olive oil.
Many people assume that food has been analyzed to determine the nutrient content listed on the label. This is not necessarily true. Testing can be expensive, and FDA policy encourages the use of nutrient databases to determine the nutritional values of many foods. Unfortunately, this practice does not take into account the fact that nutrient values vary widely, based on factors such as cultivar or variety, species, regional origin, soil quality, maturity at harvest, length of storage, and processing methods.[28]
The FDA uses a three-tiered system to regulate the accuracy of nutrient values.[29] Fortified foods – those with added vitamins, minerals, fiber, etc.- must contain at least 100 percent of the amount listed on the label for each of the added ingredients. This strict standard means that these products may contain more – sometimes much more – than the listed value in order to ensure compliance. “Undesirable” nutrients (which include calories, sugars, total fat, saturated fat, cholesterol, and sodium) must be present at 120 percent or less, which may result in label values that are overestimated. All other naturally occurring nutrients must be present at 80 percent or more, which may result in underestimated values.
On the whole, the NLEA has provided the public with important nutrition information on food labels. However, there are still some significant gaps that conscientious consumers should be aware of. By far, the most important step in choosing healthful foods for your family is to read the ingredient list for all the products you buy. If the food is indeed healthful, the list should generally be fairly short and the ingredients both familiar and pronounceable.
Proposed changes to the nutrition facts label
The FDA has published two proposed rules amending the labeling regulations for conventional foods and dietary supplements. The changes include the following:
- Revise serving sizes to reflect amounts commonly consumed by the U.S. population today, which would result in larger serving sizes for many products
- Require more packaged foods that are generally eaten at one sitting to be considered single servings
- Require mid-size packages that could be eaten at either one or multiple sittings to list dual values: per serving and per package
- Remove “calories from fat” from the Nutrition Facts Label
- Require “added sugar” to be listed separately under “sugars”
- Update daily values for sodium, fiber, and vitamin D
- Require potassium and vitamin D amounts to be given for all products; vitamins A and C will no longer be listed
- Revise the label design and display the calorie count in larger type
The FDA is accepting comments about these changes until August 1, 2014. The proposed rules are Nos. 2014-04387 and 2014-04385 in the Federal Register and can be accessed online at www.federalregister.gov.
About the Author
Jennifer Handy, PhD, teaches English in the San Francisco Bay area. She has published work in literature and composition journals as well as past issues of the PPNF Journal. After reading Nutrition and Physical Degeneration, she became interested in nutrition and began eating whole foods, drinking raw milk, and grinding her own grains. Contact her at: [email protected].
REFERENCES
- Food and Drug Administration. Flavored milk; petition to amend the standard of identity for milk and 17 additional dairy products. Fed Regist. 2013; 78:11791.
- Implied Nutrient Content Claims and Related Label Statements, 21 C.F.R. Sect. 101.65 (2013).
- Whole Wheat Bread, Rolls, and Buns, 21 C.F.R. Sect. 136.180 (2013).
- Shapiro R. A comprehensive review of the Nutrition Labeling and Education Act regulations. In: Shapiro R, ed. Nutrition Labeling Handbook. New York, NY: Marcel Dekker, Inc.; 1995: 125-225.
- Summers JL. Food Labeling Compliance Review. 4th ed. Ames, IA: Blackwell Publishing; 2007.
- Food and Drug Administration. Food labeling; gluten-free labeling of foods. Fed Regist. 2013; 78:47154.
- Nutrition Labeling of Food, 21 C.F.R. Sect. 101.9 (2013).
- Food Safety and Inspection Service. Nutrition labeling of single-ingredient products and ground or chopped meat and poultry products. Fed Regist. 2010; 75:82148.
- Nutrition Labeling of Raw Fruit, Vegetables, and Fish, 21 C.F.R. Sect. 101.42 (2013).
- U.S. Department of Agriculture. USDA National Nutrient Database for Standard References. http://www.ndb.nal.usda.gov. Updated December 7, 2011.
- Food; Exemptions from Labeling, 21 C.F.R. Sect. 101.100 (2013).
- U.S. Department of Agriculture. National Organic Program. http://www.ams.usda.gov/AMSv1.0/nop. April 30, 2014.
- Product Composition, 7 C.F.R. Sect. 205.301 (2013).
- Multi-Ingredient Packaged Products with Less Than 70 Percent Organically Produced Ingredients, 7 C.F.R. Sect. 205.305 (2013).
- Livestock Feed, 7 C.F.R. Sect. 205.237 (2013).
- Troxel TR. Natural and organic beef. University of Arkansas. FSA3013. http://www.uaex.edu/publications/pdf/FSA-3103.pdf. Accessed May 23, 2014.
- Chert Hollow Farm, LLC. Dropping organic certification. http://www.cherthollowfarm.com/2014/03/dropping-organic-certification-part-i. March 12,2004.
- Food; Designation of Ingredients, 21 C.F.R. Sect. 101.4 (2013).
- Sucrose, 21 C.F.R. Sect. 184.1854 (2013).
- Flour, 21 C.F.R. Sect. 137.105 (2013).
- Schwartz GR. In Bad Taste: The MSG Syndrome. New York, NY: Signet; 1988.
- Ingredients Statement, 9 C.F.R. Sect. 381.118 (2013).
- Misbranded Food, 21 U.S.C. Sect. 343 (2013).
- Definitions, 21 U.S.C. Sect. 321 (2013).
- Food and Drug Administration. Draft guidance for industry: voluntary labeling indicating whether foods have or have not been developed using bioengineering; availability. Fed Regist. 2001; 66:4839.
- Reference Amounts Customarily Consumed Per Eating Occasion, 21 C.F.R. Sect. 101.12 (2013).
- Bruns P, Callen C. Cereal and bakery products: the Nutrition Labeling and Education Act challenge. In: Shapiro R, ed. Nutrition Labeling Handbook. New York, NY: Marcel Dekker, Inc.; 1995:495-508.
- Heimbach JT, Egan SK. Compliance with nutrition content declaration requirements. In: Shapiro R, ed. Nutrition Labeling Handbook. New York, NY: Marcel Dekker, Inc.; 1995:509-550.
- Bender MM, Rader JI, McClure FD. Guidance for Industry: Nutrition Labeling Manual – A Guide for Developing and Using Data Bases. http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm063113.htm. Published March 17, 1998. Updated May 18, 2014.
Published in the Price-Pottenger Journal of Health & Healing
Summer 2014 Volume 38 Number 2
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