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1 From the Grocery Manufacturers Association, Washington, DC.
2 Presented at the ASNS/ASCN Public Information Committee Symposium "Dietary Reference Intakes (DRIs) for Food Labeling," held in San Diego, CA, 4 April 2005. 3 Address reprint requests and correspondence to AJ Kretser, Scientific and Nutrition Policy, Grocery Manufacturers Association, 2401 Pennsylvania Avenue, NW 2nd Floor, Washington, DC 20037. E-mail: akretser{at}gmabrands.com.
ABSTRACT
The food industry appreciates the complexity of applying the new Dietary Reference Intakes (DRIs) in labeling. The industry is prepared to update food labels to reflect new nutrient recommendations and views upcoming changes as an opportunity to harmonize nutrition information across the Dietary Guidelines for Americans 2005, MyPyramid.gov, and the food label. Members of the Grocery Manufacturers Association are unanimous in their belief that the food label be as useful to consumers as possible. This article raises discussion points, issues, and implications associated with implementation of the new DRIs on the food label.
Key Words: Dietary Reference Intake • DRI • Daily Value • DV • food industry • dietary guidelines
INTRODUCTION
Focus group research shows that consumers are interested in buying healthful foods and beverages and in using the food label to choose items that satisfy personal health goals. Toward those ends, the Grocery Manufacturers Association (GMA) concurs that the role of the Nutrition Facts panel on the food label is to provide factual nutrition information about a product. The GMA also supports that the Nutrition Facts panel reflect federal nutrition recommendations and guidelines and continue to be based on a 2000-calorie diet as in Dietary Guidelines for Americans 2005 (1) and MyPyramid.gov (2).
NEW DAILY VALUES FOR NUTRIENTS
The process of updating the Daily Values (DVs) on the food label on the basis of the new Dietary Reference Intakes (DRIs) will require careful deliberation about whether the revised DVs will increase or decrease from current values. Those decisions could well have an impact on future product formulations.
MANDATORY MICRONUTRIENTS
Existing mandatory labeling includes vitamins A and C, iron, and calcium; the GMA believes the process of updating the DVs provides an opportune time to evaluate whether changes in mandatory micronutrients might be appropriate, for example, adding potassium, which is emphasized in the Dietary Guidelines 2005 for its role in modulating blood pressure. The GMA is not prepared to promote any particular change or changes at this time. Rather, it is asking the government to carefully consider which micronutrients to include in the Nutrition Facts panel. The organization notes that food manufacturers respond to public health issues such as a need for more calcium in the American diet with the introduction of new products that are a "good" or "excellent source" of calcium or through fortification of products. The GMA points out that different mandatory micronutrients as well as new DVs for macro- and micronutrients required in the Nutrition Facts panel may influence industry decisions on product formulations and fortification levels of both new and existing products.
THE DIETARY GUIDELINES 2005
The GMA supports the use of the Dietary Guidelines 2005 (1) as the basis for federal nutrition policy and believes that the guidelines should be the basis for each direct touch point with consumers, including MyPyramid.gov (2) and the Nutrition Facts panel on the food label. The Dietary Guidelines encourage most Americans to eat fewer calories, be more active, and make wiser food choices. The Nutrition Facts panel on the food label is the tool consumers use to make those choices.
GUIDING PRINCIPLES: THE DRIs
In preparation for the proposed revision to the DVs on the food label in response to the DRIs (Table 1), the GMA examined 5 of the 16 guiding principles as outlined in the Institute of Medicine report Dietary Reference Intakes: Guiding Principles for Nutrition Labeling and Fortification (4). After each of these 5 guiding principles below are some observations and views intended to raise discussion points rather than provide a stated position of the food industry on this issue. Full consideration of the issues and implications has yet to be determined by GMA member companies.
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TABLE 1. Glossary of terms related to the new Dietary Reference Intakes (DRIs)1
Guiding principle 1: nutrition information in the Nutrition Facts panel should continue to be expressed as %DVs
As stated in the final rule of the Nutrition Labeling and Education Act, "expressing the level of a nutrient in the food as a percent of a reference amount (the DV) was intended to be a simple and straightforward way of permitting the consumer to understand the amount of a nutrient in the context of the total daily diet." However, it is not entirely clear that consumers find the DV to be as useful as originally intended. The GMA believes that the Food and Drug Administration (FDA) should conduct further consumer research to better understand how consumers interpret %DVs. If the FDA retains the %DV concept, then the GMA supports stepped-up educational efforts to help consumers understand the concept.
Guiding principle 2: the %DVs should be based on population-weighted estimated average requirements or adequate intakes
With the use of this model, the DVs would not reflect the needs of most Americans. A population-weighted Estimated Average Requirement (EAR), by definition, ensures that only 50% of the population will meet nutrient adequacy at any given time. Furthermore, as the population ages, the weighted average would drive the EARs or Adequate Intakes (AIs) even lower for some nutrients.
The DV for iron, for example, is currently set at 18 g. A population-weighted average would reduce that EAR to 6 g (a 66% decline). It would reduce folate by 22%, from 400 to 314 µg. The effects of a shift to basing the DVs on population-weighted EARs or AIs on minerals, vitamins, and fiber are shown in Table 2, Table 3, and Table 4.
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TABLE 2. Difference among existing Daily Values (DVs) based on the highest Recommended Dietary Allowance (RDA) for all population groups1
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TABLE 3. New Daily Values (DVs) based on population-weighted Estimated Average Requirements (EARs) or Adequate Intakes (AIs)1
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TABLE 4. Daily values (DVs) using the new Recommended Dietary Allowance (RDA) values based on the highest RDA for all population groups1
With the use of this model, there will be increases and decreases in population-weighted DVs from existing DVs. Shown in Tables 2-4 are the differences among existing DVs based on the highest Recommended Dietary Allowance (RDA) for all population groups, the new DVs based on population-weighted EARs or AIs, and DVs using the new RDA values based on the highest RDA for all population groups. If the FDA adopted this guiding principle, the industry would feel compelled to list the actual amounts of nutrients (eg, 18 g Fe) in the Nutrition Facts panel on the food label to ensure that consumers are not misled about the actual amount of the nutrient in the food. The GMA notes that individuals, not populations, use food labels.
This model also provides less protection for at-risk groups. The Dietary Guidelines 2005 protect at-risk population groups, including women of childbearing age and minority populations, by stressing that they should eat more of certain key nutrients. For adults, nutrients of concern identified by the Dietary Guidelines 2005 include calcium, potassium, fiber, magnesium, vitamin A (as carotenoids), vitamin C, and vitamin E; for children, they include calcium, potassium, fiber, magnesium, and vitamin E. Specific at-risk groups, nutrients of concern, the percentage of the population that includes these at-risk groups, and decreases in DVs if a population-weighted EAR approach were adopted are shown in Table 5. DVs, if calculated on the basis of a population-weighted EAR or AI, would afford far less protection. Such calculations may also reduce the apparent need for certain vitamins and minerals. For example, a young adult female might read in the Nutrition Facts panel on the food label that a food contains 2 g Fe and 33% DV and assume that she is consuming 33% of her DV for iron; in fact, for women of childbearing age, this amount represents only 11% of the actual DRI.
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TABLE 5. Comparison of Daily Values (DVs) for at-risk population groups1
Guiding principle 5: the acceptable macronutrient distribution ranges should be the basis for the DVs for the macronutrients protein, total carbohydrate, and total fat, and the Institute of Medicine report recommends using the midpoint of the acceptable macronutrient distribution ranges (AMDRs) for the DV for total carbohydrate and total fat, with the DV for protein based on the difference [100 – (DV for carbohydrate + DV for fat)]
The 2 labeling options under consideration for macronutrients are use of the range of AMDRs for carbohydrate, fat, and protein or use of the midpoint of the AMDRs for total carbohydrate and fat, with the DV for protein based on the difference. The AMDR midpoint approach for fat could have unintended consequences on consumer perception of certain foods. A consumer may think that a food is too high in fat when in fact it falls within public health recommendations for the prevention of chronic disease. Furthermore, for many individuals, fat provides desirable qualities to foods to make diets more palatable and, therefore, more sustainable in the long term. The Dietary Guidelines 2005 recognizes that the type of fat is more important than amount of total fat.
Guiding principle 7: the DVs for saturated fat, trans fat, and cholesterol should be set at a level that is as low as possible in keeping with an achievable health-promoting diet, and the Institute of Medicine committee recommends a combined %DV for saturated and trans fat
Menu-modeling techniques that create menus with extreme low levels of fat must be evaluated against achievable health-promoting diets for diverse ethnic populations in America identified in national dietary surveys. National dietary surveys provide information on typical dietary patterns of Americans from different ethnic backgrounds. Drastic changes in these typical dietary patterns are not sustainable on a population-wide basis.
The new approach of a combined %DV for saturated and trans fat shifts the focus of labeling from a chemical structure to that of physiologic impact. This potential change raises many issues, including 1) whether saturated fat should exclude stearic acid, because stearic acid has been shown not to contribute to cholesterol raising; 2) whether dietary fiber should be separate from total carbohydrates, because it has health-promoting properties; and 3) whether resistant starch should be separate from other carbohydrates or included in dietary fiber because it too has health-promoting properties.
Guiding principle 10: absolute amounts should be included in the Nutrition Facts for all nutrients
For an unknown proportion of consumers, use of absolute values for a vitamin or mineral (eg, 600 mg Ca) rather than %DVs should increase understanding of how the information on the Food Label can affect their health.
CONCLUSION
The consumer is the final arbiter of whether the food label succeeds or fails in its mission to help consumers make healthy food choices. As a critical component of US nutrition policy, the label should reinforce dietary recommendations presented in the Dietary Guidelines 2005 and at MyPyramid.gov. It should reflect the latest science in ways that are useful, understandable, and meaningful for consumers.
ACKNOWLEDGMENTS
AK was responsible for the conception, research, editorial oversight, and critical review of this manuscript and vouches for its content. The author is employed by the Grocery Manufacturers Association.
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