Ought to there be a voluntary “wholesome consuming” image? Kroger rings in

Posted on Regulations.gov, here is a comment from Kroger to the FDA on the subject of a voluntary symbol representing the “healthy” nutritional statement on packaged foods.

Comments on the topic are due July 6th.

I find it interesting that Kroger is working with the FDA to ensure that fresh, mass-produced goods without a label should still bear the “healthy” symbol clearly visible.

Kroger writes: “While it may seem obvious that fruits and vegetables are healthy choices, patients have asked our nutritionists whether bananas or berries are healthy because they assume that some products contain more sugar than others and are therefore not a healthy choice “Krogerger said in the comment.

The full comment from Kroger:

As America’s largest traditional grocery retailer, simplifying health information to help people lead healthier lives is a top priority. Kroger supports the proposed quantitative research to identify a relevant, effective symbol to represent the “healthy” nutritional indication for Americans. The use of online surveys reduces participant and administrative effort and at the same time expands the scope of research. The information gathered during these studies will have practical use in effectively helping customers choose healthier options.

Defining “healthy” and communicating healthy options to the public is not an easy task. It can be challenging to summarize the many attributes of a food or beverage product into a single consumer-centric representation. We also recognize that the many different publicly available nutrition assessment systems designed to facilitate healthy choices may have different thresholds for what is considered “healthy”, which can create confusion for consumers. The FDA’s important work will help private and public industries focus on a unified definition of health and improve consumer understanding for better choices.

While we support the proposed research, we have a few suggestions that we can use to improve the proposed research and results:

1) Our team of nutritionists emphasizes the importance of gradual changes. In our own nutrition evaluation system OptUP, customers have the option of choosing a similarly better product with a higher OptUP rating. We strongly believe that small improvements in eating habits over time are the key to sustainable change. While we see the value of an overarching “healthy” symbol, we also see challenges related to a black and white mindset that may better discourage you for articles that do not meet the proposed definition of healthy, but still contain healthy properties. There is a risk of consumer confusion with these gray items. Take, for example, if a breakfast cereal with 10 g added sugar but 5 g fiber per serving does not have a “healthy” symbol. While the Dietary Guidelines 2020-2025 recommend limiting added sugar for Americans, the guidelines also recommend consuming fiber. Our Suggestion: Consider having participants compare items with a “healthy” symbol and an item with healthy properties that may not meet the FDA’s proposed definition of healthy to assess the possible unintended consequences of discouraging articles that provide important nutrients.

2) We want to review the potential challenges of a “healthy” symbol. Our nutritionists understand that what is considered “healthy” is variable and individual, including personal health history. What is healthy for some may not be healthy for others. To ensure that the FDA is providing comprehensive and positive guidance to consumers, we suggest testing other potential symbolic terms (e.g., “nutritious”, “nutritious”) in Study 1 of the proposed study.

3) Make sure that the “healthy” symbol is clearly visible for fresh products without a label. While it may seem obvious that fruits and vegetables are healthy choices, patients have asked our dietitians whether bananas or berries are healthy because they assume that some products contain more sugar than others and are therefore not a healthy choice. The lack of a “healthy” symbol can confirm misconceptions. For example, we don’t think it’s necessary to put “healthy” stickers on individual apples, but labeling is required in the vegetable department. Perhaps Study 1 could include in-depth questions on the use of the “healthy” symbol in relation to products and where the placement of this symbol could best be used by the consumer.

4) The proposed symbols 14a, 14b and 15a, 15b are similar to the USDA Organic Label with a rounded border, half-colored center, agency name above and qualifier below. We warn against using these suggested symbols in the last rule in order to avoid equating “organic” with “healthy” or to confuse consumers with the symbols.

We appreciate the FDA’s continued work in this area to simplify healthy eating and help consumers lead healthier lives.

Kroger health
555 Race Street, Cincinnati, OH 45202

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