The FDA has proposed changes to the Nutrition Facts label (NFL) and is expected in the next few months to finalize what will be significant modifications to nutritional labeling. These will be the most dramatic changes for nutrition policy in over 20 years. The changes are in response to evolving health and wellness consumer trends and the demand for more information and transparency.
The key proposed rule changes to date for the Nutrition Facts label include:
- No longer permit stating “Calories from fat”
- Changes to nutrient content claims
- Mandatory listing of vitamins and minerals
- Mandatory listing of added sugars
- Updated daily values for vitamins and minerals
- Definition for dietary fiber
- Record keeping to validate naturally occurring and added sugars, folate and folic acid, dietary fiber and non-digestible carbohydrates that do not meet the definition of dietary fiber
The proposed updates will become effective within 60 days from the final ruling. Retailers and brand owners will have two years to complete implementation (for their entire portfolio of products).
How do the proposed changes to the Nutrition Facts label impact on private brands?
There are many considerations to take into account with the proposed changes to the Nutrition Facts label:
1. Brand image
- Do declarations change the way that consumers think about the brand?
2. Label design
- New packages will have to be printed with reformatted NFLs.
- Should other packaging changes be made to bring label design in line.with NFL design? For example, font size, typeface, spacing; will this be the trigger for a broad brand re-design?
- Should products be reformulated to maintain health claims and nutrient content claims?
- Should products that appear less attractive to consumers as a result of the new NFL format be reformulated?
4. Record keeping requirements
Based on these considerations, retailers must decide whether to simply re-label products, re-package them, reformulate or remove them from shelves.
Where to begin within a portfolio of private brand products?
The process of compliance within this very limited implementation window will require a well-planned execution plan. The plan should include decision making criteria, resource needed, and the technology required in order to control complexity and cost. In addition, it is imperative that the plan should aim to utilize supply chain partners using really good engagement processes.
The ideal process will only touch each package once with the goal being to execute one design change for each package. Every touch point must count.
In order to plan and execute label transition decisions, retailers need to understand the scale of risk within their entire portfolio of private brand products.
The first step in preparing for the transition is to conduct an impact analysis.
1. What is the impact of the new requirements on each product relating to:
- Nutrition Fact label size
- Nutrient declarations
- Nutrient content claims
- Serving size
- Amount of added sugars
- Dual column format
2. How do the changes impact the current source of supply?
3. What behavioral changes might the new NFLs cause among consumers that purchase the brand?
Carrying out an impact analysis will provide the facts needed to create a phased transition plan across an entire line of products. This categorical approach will highlight missing information, a process which is essential for planning the execution of changes and scheduling of any re-labeling, re-packaging and reformulating efforts.
We experienced similar challenges in Europe with FIR – the Food Information Regulation - which required all suppliers to have understood the regulation and updated their product information and packaging accordingly – or the products would be removed from the shelves.
These changes were similarly material changes to NFL requiring the packaging on almost all private brand products to be overhauled. We worked with a number of retailers using supplier engagement to effect this change.
In summary, the proposed changes to the Nutrition Facts label should be a strategic priority for private brand retailers. Waiting to start this initiative is not an option.