Front-of Pack Nutritional Labelling (FOPNL) systems – in the form of mandatory nutrition warnings, scoring and color-coded scales based on nutritional profiles, and healthy logos (i.e. Nutri-Score), both mandatory and voluntary – continue to spread across five continents, aligning with nutritional safety needs and WHO (World Health Organization) recommendations. (1)
On January 14, 2025, the Food and Drug Administration (FDA, USA) proposed a mandatory front-of-pack nutrition label to ‘provide accessible and immediate information that helps consumers quickly and easily identify how foods can be part of a healthy diet.’ (2) The current state is as follows.
1) Front-of-Pack Nutrition Labelling (FOPNL), the state of art in the world
FOPNL (Front-of-Pack Nutrition Labelling) is a system of front-of-pack nutritional labeling already adopted, in development, or under implementation in several countries worldwide:
a) ‘mandatory nutrition warnings.’ Obligations already established in Argentina, Bolivia, Brazil, Canada, Chile, Colombia, Mexico, Peru, Uruguay, Venezuela, Iran, Israel, Thailand, Singapore, Sri Lanka;
b) ‘mandatory nutrition warnings.’ Work in progress in Barbados, Costa Rica, Guatemala, El Salvador, Jamaica, Panama, USA, Cameroon, Ghana, Ethiopia, Kenya, Tanzania, Uganda, South Africa, India, Pakistan, Philippines;
Source: FOPWL regulations around the globe. Global Health Advocacy Incubator. Last updated June 2023 https://tinyurl.com/ye279hkc
c) ‘voluntary FOPNL.’ Nutri-Score is the most widespread and appreciated system in Europe (Austria, Belgium, France, Germany, Luxembourg, Netherlands, Portugal, Romania, Spain, Switzerland), followed by the ‘Keyhole System’ (Norway, Sweden, Iceland, Denmark, Lithuania, North Macedonia) and the historic ‘Multiple Traffic Light System’ in the UK. Other national systems are applied in the Netherlands, Denmark, Finland, Slovenia, Croatia, and Italy.
Voluntary FOPNL systems are also applied in Nigeria, Zambia, Zimbabwe, and South Africa, Israel, Saudi Arabia, United Arab Emirates, China, Thailand, Indonesia, Malaysia, Singapore, Brunei, South Korea, Philippines, Australia, and New Zealand. (1)
2) USA, ‘Nutrition Info box.’ The FDA proposal
The front-of-pack nutrition labeling (FOPNL) proposed by the FDA, open for public consultation until May 16, 2025, consists of a ‘Nutrition Info’ box – in a specific format, using black and white colors – that includes:
– the display of values for saturated fats, sodium, and added sugars as percentages of the recommended daily intake (‘% daily value’) for each, based on a ‘serving size,‘ expressed in ‘household measures,’ e.g., ‘Per serving (whole package)’ or ‘Per serving (1/2 cup)’; (3)
– the interpretation of these three values: ‘Low’ when the serving provides <5% of the daily value (DV) for saturated fats, sodium, and added sugars; ‘Med’ if the intake is in the range of 6%-19% of the corresponding DV; ‘High’ when the intake exceeds 20% of the DV;
– the indication ‘FDA.gov,‘ at the bottom of the ‘Nutrition Info’ box, to strengthen consumer trust in the data provided;
– the option to include the caloric value (Kcal), also based on the ‘serving size,’ in a separate box below or in an oval to the right of the ‘Nutrition Info’ box. However, the caloric value remains mandatory in the full ‘Nutrition Facts’ table.
2.1) Nutrient claims, partial revision
The ‘Nutrition Info’ box is part of broader FDA nutritional policies, including updates to the requirements for using the term ‘healthy’ on food labels.
FDA also proposes revising the rules for nutrient claims to:
– sodium. The limit for the voluntary ‘low sodium’ claim should be reduced from 140 to 115 mg per RACC (Reference Amount Customarily Consumed) or 100 g, in line with current nutritional science; (4)
– ‘nutrient claims’. Use of the NC ‘low sodium’ and ‘low saturated fats’ should be precluded for products that do not meet the requirements (<5% DV per ‘serving size’) to report the respective ‘low’ values in the ‘Nutrition Info’ box.
3) ‘Nutrition Info’ and GDAs: similarities and differences
The ‘Nutrition Info’ box system is based on the GDAs (Guideline Daily Amounts) system, previously developed and imposed by Big Food on European legislators. (5) However, it adds an interpretative layer (Low, Med, High), which, while valuable, is based on relative and partial values. The ‘Nutrition Info’ box refers only to:
– serving size rather than 100 g/ml of product, as recommended by WHO. (6) This approach limits the ability to compare nutritional values across products, though in the USA, this is mitigated by standardized serving sizes for product categories; (7)
– percentage values based on a daily value, i.e., the recommended amount of nutrients for an ‘average adult.’ This can mislead population groups with lower or higher needs (e.g., children, women under 70 kg, or individuals over 70 kg);
– ‘negative’ nutrients (those to be controlled or reduced), without considering ‘positive’ values (e.g., proteins, fiber, fruits, nuts, and olive oils) that can partially balance nutritional profiles. (9)
4) Nutri-Score: a missed opportunity for the USA
The ‘Nutrition Info’ box scheme is derived from two focus groups conducted by FDA, in 2008 and 2022, and a subsequent experimental study of 9,200 U.S. adults, members of an online consumer panel, based on a web questionnaire.
FDA studies, however, considered variations on only four Front-of-Pack Nutrition Labeling (FOPNL) schemes then on the U.S. and international market in 2008:
– Guideline Daily Amounts (GDAs);
– Nutrition Tips;
– Nutrition Tips-High In;
– High In.
Nutri-Score, the most widespread and scientifically supported FOPNL system in Europe, aligned with WHO and Codex Alimentarius recommendations (10,11,12,13), was not included in the FDA’s analysis. This represents a significant missed opportunity.
5) Provisional conclusions
The global syndemic – a pandemic of serious and chronic diseases (Non-Communicable Diseases, NCDs) associated with unbalanced diets, obesity, and overweight – should prompt all decision-makers to introduce mandatory FOPNL without delay.
Nutri-Score system, as confirmed by a recent OECD comparative study, is more comprehensive and effective than other systems. (11) Its global adoption should be promoted with the following objectives:
– extend global governance, with decisions by the Steering Committee based on recommendations from an independent scientific committee and stakeholder contributions; (14)
– provide citizens worldwide with simple, uniform, and essential information for making food choices and understanding their role in diets based on updated dietary recommendations;
– collect and share uniform data on the nutritional quality of millions of food products across countries, as already achieved through Open Food Facts, serving the global stakeholder community.
Dario Dongo
Footnotes
(1) FOPWL regulations around the globe. Global Health Advocacy Incubator. Last updated June 2023 https://tinyurl.com/ye279hkc
(2) FDA Issues Proposed Rule on Front-of-Package Nutrition Labeling. FDA, presr release. January 14, 2025 https://tinyurl.com/4fepr2bx
(3) The exact quantity of the portion – in units of weight or volume – is instead specified, next to the ‘household measure’, in the complete nutritional table (‘Nutrition Facts’) which is also mandatory.
(4) Nutrition Facts label final rule (2016) has in fact decreased the DRV (Daily Recommended Value) for sodium, from 2.400 mg to 2.300 mg (from 6 to 5,75 g of salt). This revision derives from the consensus on the need to reduce sodium intake, ‘since there is a direct relationship between sodium intake and increased blood pressure‘
(5) Food Information Regulation (EU) 1169/11 has in fact introduced the so-called Reference Intakes, as voluntary information to be reported on the front of the food label, in contrast to an interpretative FOPNL, such as the traffic-light system already widespread in the UK. And it was only the obstinacy of the rapporteur to the European Parliament Renate Sommer, in the second reading of the proposal, that made it mandatory to report at least the energy value also at 100 g/ml of product (article 33.2, paragraph)
(6) See paragraph 1.c of the previous article by Dario Dongo. NutriScore and Nutriform, Professor Serge Hercberg provides clarity. FT (FoodTimes).April 20, 2023
(7) In the European Union, on the contrary, operators can freely establish the quantity (often unrealistic and inhomogeneous, between products of various brands within the same product categories) of the portions
(8) Food Information Regulation (EU) 1169/11 in turn provides that the ‘Guideline Daily Amounts’ (GDAs), renamed ‘Reference Intakes’, are limited:
– to the energy value only (per portion and per 100 g/ml), or
– energy value (per portion and per 100g) and fat, saturated fat, sugars and salt (article 30.5)
(9) FDA recalls that the ‘Dietary Guidelines for Americans, 2020-2025 recommend, among other things, limiting intake of saturated fat, sodium, and added sugars to achieve healthy eating patterns‘. However, privileging the synthesis of information, on the basis of the preferences expressed by US consumers in the context of the two studies coordinated by it
(10) Dario Dongo, Andrea Adelmo Della Penna. How to solve the nutritional conundrum? News on the label front, review and perspectives. GIFT (Great Italian Food Trade).
(11) Marta Strinati. NutriScore and three other nutritional labels compared. OECD study. FT (FoodTimes). February 16, 2024
(12) Dario Dongo, Andrea Adelmo Della Penna. European Commission, research confirms NutriScore approach. FT (FoodTimes). September 14, 2022
(13) Dario Dongo. Codex Alimentarius, the NutriScore and the WHO guidelines. FT (FoodTimes). September 29, 2021
(14) See paragraph 1 (NutriScore, governance and evolution of the algorithm) of the previous article by Dario Dongo. NutriScore, evolution of the science-based algorithm. FT (FoodTimes). August 1, 2022
(13) Dario Dongo. Codex Alimentarius, the NutriScore and the WHO guidelines. FT (Food Times). September 29, 2021
(14) Si veda il paragrafo 1 (NutriScore, governance and evolution of the algorithm) al precedente articolo di Dario Dongo. NutriScore, evolution of the science-based algorithm. FT (Food Times). August 1, 2022
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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