Decoding Front-of-Package Food Labels: Are They Really Telling Us What’s Healthy?
How do we know what is healthy? Given the link between healthy eating patterns and diet-related diseases, consumers need accurate information to make informed choices about which foods they should purchase.
How do we know what is healthy? Given the link between healthy eating patterns and diet-related diseases, consumers need accurate information to make informed choices about which foods they should purchase.
This is the driving motivation behind the U.S. Food and Drug Administration’s (FDA) new proposed rule on a front-of-package nutrition label, called a “Nutrition Info box.” It would detail the relative amounts of three nutrients—saturated fat, sodium, and added sugar—on each food package’s front (through “Low,” “Med,” or “High” descriptions) so that it is immediately visible to consumers. Front-of-package labeling has the potential to increase nutrition information, and therefore dietary health.
History of Food Labeling in the U.S.
From 1941 to the 1970s, FDA recommended food labels be used only for food products designed for special diets to treat physical and pathological conditions. Otherwise, there was little need for nutrition labels since most meals were prepared in the home with basic ingredients. In 1972, as the number of processed foods increased, FDA proposed voluntary nutrition labeling information on packages, which would only be mandatory when nutrient claims (i.e., high in fiber) were made. The voluntary regulation was finalized in 1973, requiring the mostly optional labels to include calories, protein, carbohydrates, and fat.
In July 1990, FDA published proposed rules for mandatory nutrition labeling. Congress, increasingly concerned about processed foods on the market, passed the Nutrition Labeling and Education Act (NLEA) in November 1990, granting FDA explicit authority to design and require nutrition labeling. In the decades since NLEA was enacted, FDA has gradually updated the nutrition label. However, the rise in diet-related chronic diseases highlights shortcomings of the current label, prompting the front-of-package food labeling proposal under section 403(q) of the FD&C Act.
Front-of-Package Food Labeling in the EU
The European Union (EU) has also recently implemented harmonized front-of-package nutrition labeling. “Nutri-Score” classifies packaged foods and beverages using school-like letter grades and a color scale ranging from A (green) to E (red). The labeling system was developed in 2017 by the French public health agency and has been implemented by France, Belgium, Spain, Netherlands, Switzerland, and Germany. Adoption of the standardized system has been recommended by both the European Commission and World Health Organization (WHO). The score is awarded on the basis of nutrients in food to promote fibers, proteins, fruits, vegetables, legumes, nuts, rapeseed, walnut, and olive oil and to limit energy, saturated fatty acids, sugars, and salt.
Within the EU, countries like Italy and Greece have rejected implementing the Nutri-Score, arguing that it discriminates against the traditional Mediterranean diet, which tends to be higher in fat and salt. Many in the food industry also argue that Nutri-Score disadvantages traditional produce, which does not receive any score indicating its healthfulness since it is not packaged. Additionally, Nutri-Score was designed to compare the nutritional value of products within food categories (i.e., crackers to crackers, not crackers to chips) rather than to be used as a blanket score by which to compare all packaged foods that can be found in a single store. Since many consumers may not be aware of the nuanced use of the standardized label, the score listed on a package may instead mislead consumers to still make uninformed choices unintentionally.
The Future of Front-of-Package Labeling
When FDA created the nutrition panel familiar to consumers today, the agency based which nutrient and food components were to be required on two sources: The Surgeon General’s Report on Nutrition and Health and the National Research Council’s (NRC) report Diet and Health: Implications for Reducing Chronic Disease Risk. With the documents as reference, FDA chose which nutrients to list on the labels based on whether they were both (1) of public health significance, and (2) part of a specific quantitative recommendation by a scientific organization. But these criteria had limitations. For example, there was no scientific evidence at the time that the body processes added and naturally occurring sugars differently, thus there were no specific quantitative recommendations for total sugars. And debates over trans fat inclusion illustrate a similar story: At the time, FDA concluded that trans fat did not contribute to increased LDL-cholesterol levels. Shortly after, new data suggested that trans fat did contribute to higher levels. In 2003, FDA issued a final rule requiring trans fat to be listed independently of saturated fat.
Today, the U.S. and EU food labeling regimes continue to be based on the best available scientific knowledge as applied to a general population. However, nutrition needs vary greatly by person and the best available science on a nutritious diet is constantly evolving. While FDA currently believes that saturated fat, sodium, and added sugar are the three greatest contributors to diet-related diseases, and should therefore be avoided, other experts argue that the front-of-package label should instead highlight whether products contain high levels of key nutrients to encourage purchasing rather than focus on high levels of nutrients in products to avoid.
In recognition of varying needs across populations, EU’s Nutri-Score considers the whole nutrient profile of the food product in its algorithm rather than focusing on a few key nutrients. Despite the EU’s more holistic review process, FDA consumer research found that the black and white Nutrition Info box was most effective.
Similarly to Nutri-Score, the newly proposed Nutrition Info box may also unfairly discriminate against certain cultural diets. Foods high in sodium may give consumers pause. In fact, the Mediterranean diet has often been linked to living longer despite high levels of salt and fat in traditional foods. Plainly stated, no label adequately captures what foods are needed in a well-rounded diet.
Despite some deficiencies in the proposed Nutrition Info box, nutrition labeling on processed foods is likely beneficial to consumers. Education campaigns and political attention to this issue—like President Trump’s establishment of the Make America Healthy Again (MAHA) Commission on Feb. 13, 2025, and U.S. Department of Health and Human Services (HHS) Secretary Robert F. Kennedy Jr.’s focus on healthy eating—increases awareness about informed dietary choices. Whether the proposed Nutrition Info box appropriately informs consumers’ dietary choices remains to be seen.
About the author
Jessica Samuels is a third-year dual degree law and public health student (J.D./MPH 2025). Her research interests include genetics, environmental health sciences, novel biotechnologies, and the FDA regulatory process. She has previously published work on the accuracy of ultrasound in predicting malignant ovarian masses. At HLS, Jessica is co-president of the Harvard Health Law Society.
