aci 5 th advanced regulatory and compliance summit on food and beverage marketing and advertising...
TRANSCRIPT
ACI 5th Advanced Regulatory and Compliance Summit on Food and Beverage Marketing and Advertising
Chicago, Illinois
July 29, 2014
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FDA Nutrition Labeling Revamp
What Food Companies Need to Know To Update Their Marketing
Efforts
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ORIGINAL NUTRITION FACTS LABEL HAD A MAJOR IMPACT
Original label became effective in 1994
Emphasis at that time was on fat content
More than 6,000 new “low fat” foods were introduced in the marketplace in 1996
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• Trans Fat disclosure was added in 2006
• Trans Fat content in processed foods declined by about 50%
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• New FDA revisions are High Profile
• White House led announcement followed by statement by FDA Commissioner Hamburg
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Statement of FDA Commissioner Margaret Hamburg Emphasizes:
> Calories
> Serving sizes
> Percent daily values
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Marketing Impact – Strategic Planning
Threat or opportunity – Now is the time to consider new
strategic marketing efforts Almost every company will still
have a tool kit to work with The “tools,” however, will be
different
MARKETIG IMPACT – What will the changes entail?
Let’s take a look at the proposed changes and consider the new tools that may be available to communicate the health benefits of your product
MARKETING IMPACTS – BOLDER “CALORIE” DISCLOSURES
Total calorie content of foods will be emphasized to a greater extent
FDA wants to prevent mishap in 1996 where many new “low fat” foods had as many calories as traditional counterpart
Fat was replaced with sugar
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MARKETING IMPACTS – SERVING SIZES
More than 30 serving sizes (RACCs) will change; most will increase.
Serving size for ice cream will double – that means calorie content, as well as fat, sugar, and sodium content on the Nutrition Facts label will double as well
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MARKETING IMPACTS – SINGLE SIZE SERVINGS
New rules for single size servings Will require nutrition information
for entire package What will impact be on package
sizes? Will dual column labeling be an
option?
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MARKETING IMPACT – HEALTH AND NUTRITION CLAIMS
Increasing the amount of fat, saturated fat, cholesterol and sodium listed on the Nutrition Facts panel to comply with new serving sizes and single serving regulations will impact ability to use health and nutrition claims
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MARKETING IMPACT: HEALTH AND NUTRITION CLAIMS
Health and nutrition claims are limited when fat, saturated fat, cholesterol, or sodium content exceed 20% of the Daily Value
That limit will be reached more quickly, given that higher amounts of those nutrients will have to be declared
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MARKETING IMPACT – SODIUM
The DV for sodium will increase The cutoff for health claims for
foods with 20% or more of the DV for sodium remains the same
Result: Foods making health claims may have to decrease sodium content or drop the claim
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MARKETING IMPACT – FIBER CONTENT
FDA is proposing to change the definition of fiber
Certain ingredients will no longer be counted as “fiber” for disclosure purposes on the Nutrition Facts label
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MARKETING IMPACT: % DAILY VALUES
FDA proposes to give % Daily Values (DV) greater prominence
Will be placed on left side of label
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• Alternate Format
• Issued by FDA for comment
• Reveals Agency’s true agenda
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MARKETING IMPACT – ADDED SUGARS DISCLOSURE
FDA proposes to require new line on Nutrition Facts for Added Sugar Content
Not related to disease, but rather “nutrient density”
FDA’s own definition of “Healthy” does not consider sugar content
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MARKETING IMPACT – ADDED SUGARS DISCLOSURE
Will be enforced by huge recordkeeping and inspection requirement
Recordkeeping required even if little sugars are added
FDA inspectors may request formulas and other proprietary information
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MARKETING IMPACT – ADDED SUGARS DISCLOSURE
FDA study on utility of added sugars disclosure is still ongoing; impact on consumers unclear
Consumer confusion is likely to result – Here is why:
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Current
Proposed
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MARKETING IMPACT -FRONT OF PACKAGE NUTRITION LABELING SUMMARIES
Front of pack “Facts up Front” and Wal-Mart “Good for You” symbol currently in use
FDA considering issuing federal uniform scheme
Not part of this rulemaking, but coming down the road . . .
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