We (the undersigned) welcome the opportunity to comment on the Food and Drug Administration’s (FDA) use of the term “healthy” on food labels.

Under FDA's current rules, the focus surrounds the amount of fats and the value of nutrients in foods labeled "healthy." Proposed revised rules would focus more on the type of fats, the amount of added sugars, and labeling to help consumers understand the new Nutrition Facts Panel on product packaging.

This public comment period will close April 26, 2017.

Please add your name to our comments and we will deliver them to the FDA before the deadline.

Petition: “Use of the Term ‘Healthy’ in the Labeling of Human Food Products: Guidance for Industry”

Dear FDA Division of Dockets Management:

Fair Farms would like to provide comments on the Food and Drug Administration’s (FDA) decision to further regulate the term “healthy” on food labels. We are a growing movement of over 20,000 Marylanders of all stripes working together for a new food system – one that is fair to farmers, invests in homegrown healthy food, and restores our waterways instead of polluting them.

We applaud the FDA’s efforts to redefine when food labels may contain the word “healthy,” given the large body of research on nutrition that has come out since 1994 – when the FDA first defined and set up the regulatory framework for the use of the word. For instance, the current regulatory framework prevents the use of the term “healthy” on foods like avocados, fish, and walnuts, but sugary cereals like Froot Loops with marshmallows can be labeled as “healthy.”

When consumers see the word “healthy” on a food product, they are more likely to believe the claim is truthful and ignore the nutrient label. For example, one study found that for certain food products, consumers were more likely to view the front-of-package labels including health claims instead of the actual nutrition details on the back of the product. Further, consumers believe that if a food is labeled “healthy” then it is locally sourced and free of preservatives, chemicals, and pesticides.[ii] The current regulatory definition of “healthy” does not back up these beliefs.

Whole foods, plant-based foods without added ingredients, and unrefined grains should be allowed to carry the “healthy” label outright. These include foods like fruits, vegetables, nuts, legumes, and seeds. An overwhelming body of research has confirmed the health benefits from the nutritional properties found in these foods, so the FDA should align consumer expectations with reality. This will also allow smaller farmers and producers to begin marketing their foods as “healthy” without having to undergo a costly nutritional analysis.

Achieving a just and fair food system requires going beyond simple practices we consider eco-conscious and desirable. Consumers and farmers alike deserve a better definition of what foods are considered “healthy.” This will bring us one step closer to a much-needed transformation to our food system.

Thank you for taking our comments into consideration in your decision-making process.