Justin Fink by Justin Fink

“Is this food healthy?” Health coaches and exercise professionals are undoubtedly familiar with this question from their clients.  

A proposal from the Food and Drug Administration (FDA) hopes to provide clarity to the standards for which packaged foods are eligible to be labeled “healthy.” The existing definition was adopted in 1994 and allows food manufacturers to include the word “healthy” on food packaging as long as the food meets certain criteria, including limited amounts of total fat, saturated fat, sodium and cholesterol. The product must also contribute at least 10% of the daily value of one or more of the following nutrients: vitamin A, vitamin C, iron, calcium, protein or dietary fiber. Only about 5% of all packaged foods currently qualify for the “healthy” label, according to the FDA.  

The new proposal marks a shift toward current nutrition science, as well as federal dietary guidance. It also underscores the importance of the food we consume. Currently, six out of 10 adults in the United States live with a chronic disease, including heart disease and type 2 diabetes, while four in 10 have two or more. Poor nutrition is a leading cause of illness in the U.S., and a significant risk factor for many health disorders. In fact, fewer than one in 10 adolescents and adults in the United States eat enough fruits or vegetables, while the consumption levels of added sugar, saturated fat and sodium are too high. The updated criteria are aimed at helping to improve nutrition and dietary patterns and at reducing the burden of chronic illness. 

The revised definition of “healthy” would require a pivot toward establishing that a product contains a certain amount of food from a minimum of one of the food groups or subgroups from the 2020-2025 Dietary Guidelines for Americans. These include fruit, vegetables, grains, dairy and protein foods. The new proposal would also set specific limits, based on a percentage of the set daily value, for added sugars, saturated fat and sodium. 

“Increased attention to the healthfulness of our food supply is a conscious step in the right direction, says Tiffany Holt, MS, RD, who works at the University of California San Diego Centers for Integrative Health. “With staggering increases in chronic disease, matched with a marked decrease in food quality in the modern world, we clearly need a course correction. 

While Holt posits that the new proposal is a good start, she also believes that lasting, meaningful changes will likely require additional considerations. 

It’s not a surprise that foods such as raw whole fruits and vegetables would qualify as “healthy” foods under the new proposal. Water, as well as foods such as avocados, nuts, seeds, higher-fat fish and certain oils, none of which qualify as “healthy” under the current definition, would see a reversal of that designation under the new proposal. However, foods such as highly sweetened cereal or yogurt would lose their “healthy” definition. Using cereal as an example, in order to obtain the “healthy” label, a serving size would need to contain at least three-fourths of an ounce of whole grains and no more than 1 gram of saturated fat, 230 milligrams of sodium and 2.5 grams of added sugars.  

“As a dietitian nutritionist, when considering the healthfulness of a dietary pattern, we look to wholesome foods as the most nutrient-dense options for meeting a person’s energy needs,” Holt says. “Unfortunately, this proposal is largely applied to processed and ultra-processed foods, of which there are few healthy’ products. The example in the proposal using cereal is still a processed food, albeit better than other processed options with 18 to 20 grams of sugar per serving. Instead, could we support actual whole grains such as oats and quinoa to pair with fruit, nuts, perhaps one-half teaspoon of a sweetener, and a caloric liquid, such as milk?  

Holt also suggests that an additional focus could be placed on limiting non-nutritive food additives that may play roles in poor digestion, disturbances in appetite and fullness signaling, as well as an overall ongoing contribution to noncommunicable chronic diseases. Other considerations, Holt says, could require placing the nutrition facts label and the full list of ingredients on the front of the food package, which would place less of a focus on marketing design and claims, and possibly incentivize food manufacturers to seek ingredient sourcing from naturally occurring foods. The FDA is currently studying whether to relocate the nutrition label to the front of the package in order to make it more visible. 

Ultimately, the FDA hopes this new proposal will provide consumers with an efficient visual tool that will make it easier to make informed choices about healthy dietary practices. Some research studies support the connection between providing nutrition information on packaging and healthy diets. In fact, a meta-analysis in the American Journal of Preventive Medicine concluded that food labeling can be effective in reducing consumer intake of total energy and fat, while increasing the consumption of vegetables. Further, a randomized controlled trial revealed an association between consumers who use food labels and the healthy quotient of the products purchased. 

If the rule is approved, it will be important for ACE Certified Professionals and other health and exercise professionals to become familiar with its details and nuances. The measure may represent an opportunity to provide approved nutrition information to support long-term health behavior change while staying within a defined scope of practice. 


If you are interested in gaining a deeper understanding of nutrition and learning how to help your clients make healthier food choices as part of their daily routines, consider becoming an ACE Fitness Nutrition Specialist (worth 2.5 ACE CECs).  

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