FDA should ban “healthy” label claims

Re: Docket No. Re: Docket No. FDA-2016-D-2335 2016-615, Use of the Term “Healthy” in the Labeling of Human Food Products

To the U.S. Food and Drug Administration,

PCC Natural Markets is the largest consumer-owned grocer in the United States, with 56,000
member-owners, 11 Seattle-area stores, and more than $277 million in annual sales. Our
commitment to honest labeling that doesn’t deceive shoppers is fundamental to our mission
and values and we are pleased for the opportunity to comment on “healthy” label claims.

We applaud the Food and Drug Administration’s request for public comments about the use of
“healthy” claims on food labels. The current criteria for what constitutes a “healthy” food is
severely out of date and does not reflect the current available science and understanding of
nutrition.

For instance, under the current definition of “healthy,” the following foods do not meet the
criteria, despite being endorsed by the American Heart Association and/or the 2015 Dietary
Guidelines for Americans:

1. Almonds, avocados, olive oil, flaxseed (because of fat content)

2. Eggs, seafood (because of cholesterol)
3. Salmon, chicken breast (because of fat content)
4. Milk, yogurt, extra lean ground beef (because of saturated fat content)
5. Water (no vitamins, fiber, or protein)

Rather than creating a new definition for labeling foods “healthy” we believe the best solution
is to ban the use of “healthy” on food labels. Here’s why:

1. The criteria that make foods “healthy” varies across categories of foods. It is difficult,
if not impossible, to create a one-size-fits-all criteria for healthy that accurately
describes the healthiest choices within all food groups.

For instance, beverages are healthier when lower in added sugar but chips and pretzels
are healthier when lower in sodium.

2. The healthiest foods do not have labels. The “healthy” label currently is used only for
packaged/processed foods but the healthiest foods often are whole foods that are not
packaged.

Labeling orange juice as healthy, but not oranges, adds more confusion to the
marketplace. The U.S. Department of Agriculture’s MyPlate model emphasizes that
“half your plate should be fruits and vegetables” but calling other foods “healthy” may
encourage people, erroneously, to think packaged foods may be equivalent in
nutritional value to fresh produce. It confuses and even contradicts the official goal to
encourage consumption of more fresh produce.

3. Consumers should learn what is “healthy” from nutrition professionals. Shoppers
shouldn’t rely on or trust food manufacturers (with a profit incentive) to tell consumers
what foods are healthy. Instead consumers should look to dietitians and qualified
health professionals.

4. “Healthy” claims are unnecessary. Shoppers already have access to the nutrition facts
panel and the list of ingredients. Any criteria the FDA plans to use in allowing “healthy”
claims already is found on labels for consumers to make their own decisions based on
their specific dietary needs and preferences.

5. “Healthy” is relative. Almost any food can be considered healthier than another food.
Juice is healthier than soda but water is healthier than juice. Popcorn is healthier than
cookies but fruit is healthier than popcorn. Based on this logic, almost any food could
be considered a healthy choice.

For someone who eats a diet of unprocessed vegetables, whole intact grains, and fresh
meat – foods like orange juice, corn chips, canned soup, and nutrition bars (which likely
would be labeled healthy) would actually be less healthy choices compared to the whole
foods diet.

6. Portion sizes impact healthfulness. A food may be considered healthy, based on the
serving size, but if consumed in larger portions, it may no longer be healthy. For
example, peanut butter is healthy when consumed in moderation, but if consumed in
excess, can no longer be considered healthy because of excessive calories.

7. Everyone has different dietary needs. Whole wheat bread can be healthy for one
person but harmful to someone with celiac disease. Grapefruit juice is healthy for most
people but deadly to people taking certain prescription drugs. Red wine is healthy in
moderation but harmful in excess.

8. Nutrition science changes. As new research is conducted, FDA’s definition of “healthy”
will need to be updated continuously. Today’s “healthy” definition reflects the state of
nutrition science in the 1990s, with emphasis on low-fat and cholesterol-free foods.

A modern definition would emphasize foods low in added sugars, sodium, and refined
grains. As new research is conducted and the science changes, it’s possible other
nutritional concerns will emerge that will inform our understanding of what constitutes
“healthy.” Will FDA be able update the criteria for “healthy” to keep pace?

PCC’s Nutrition Education Team spends a considerable amount of time talking with consumers
about food, nutrition, and healthy lifestyles in our free community nutrition classes in our
stores throughout the greater Seattle area. We also asked our shoppers to tell us What Should
Healthy Mean? through a survey in our monthly newsletter and also on social media, and here
is a summary of what they told us:

1. “It’s high time to revise the current FDA definition of healthy”

2. “Why not eliminate any definition, as any definition will be quickly played… An encompassing
definition will be too complicated to be useful in selecting goods off the store shelf or any usual
consumer outlet. Healthy is a concept much larger than a single food item

3. “They shouldn’t be able to market anything as healthy because it’s not definable”

4. “How can anything be labeled healthy? Peanuts are healthy for some deadly for others. Is a fine
wine healthy? For some. Not for an alcoholic. One could go on and on with these types of
examples”

5. “Everyone has different needs and the studies on what’s good for us are vast and often
conflicting”

6. “How in the world can products with added sugar be healthy?”

7. ‘“Healthy’ tends to be as vague and misleading as ‘Natural’”

Our mission at PCC includes a commitment that: “PCC members and patrons are well educated
in matters of healthful foods,” which we achieve through our advocacy, education programs,
and community outreach.

Advocating for more meaningful label claims on today’s food
products is an essential component to keeping our patrons well educated about healthy foods,
and we thank you for allowing PCC to share our unique perspective on this issue.

Nick Rose, MS
Nutrition Educator
PCC Natural Markets / Seattle, WA

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