Consumers need transparency in labeling of plant-based meat alternatives

Agenda-Setting Report Identifies Seven Priorities for Regulatory Action

June 9, 2022

Media contact: National Consumers League – Katie Brown, katie@nclnet.org, (202) 207-2832

Washington, DC – As more plant-based meat alternatives (PBMAs) that closely mimic the look, taste, and cooking properties of traditional meat products enter the U.S. market almost daily, the National Consumers League (NCL) today released a report with seven priorities for regulatory action to ensure that labels of so-called “meatless meats” readily identify the protein source and inform consumers of the nutritional composition of each PBMA product.

Issued as the U.S. Food and Drug Administration (FDA) is developing draft guidance for food manufacturers on the labeling of plant-based milks and alternatives to animal-derived foods,
the report underscores the importance of consumer-focused labeling to sustain the growth of the plant-based meats category, which has been fueled by consumer optimism. Findings were informed by an expert panel meeting held in 2021 that explored a standard of identity for PBMAs and based on an assessment of the PBMA marketplace which NCL conducted in 2022 to identify action steps that will significantly impact public awareness and understanding of PBMAs and can be readily implemented.

Providing up-to-date information on the issues affecting the labeling of plant-based meat alternatives, the report – Education and Transparency in Labeling Plant-Based Meat Alternatives: A Consumer-Focused Agenda to Improve Understanding and Decision-Making of Plant-Based Meats –documents promising projections for PBMA sales in the U.S. and globally. Recent polling shows that two-thirds of Americans (65 percent) consumed plant-based meat alternatives in 2021, and two in five (42 percent) ate PBMAs at least weekly.[1] Due to consumer demand, the plant-based meat category delivered $1.4 billion in sales in the U.S. in 2021 – up from $962 million in 2019 [2] – and a Bloomberg Intelligence report projects a 500 percent increase in global sales of plant-based foods by 2030[3]. Moreover, a recent market analysis predicts a growth rate of almost 20 percent globally for plant-based meats between 2021 and 2026 if consumer interest in PBMAs continues to grow.[4]

Yet, the NCL report points to marketplace challenges for plant-based meat substitutes. Currently, many brands define PBMAs differently and there is a lack of clarity about how to use traditional meat, dairy, and egg terminology on product labels. Additionally, only half of Americans were “very” or “somewhat” familiar with PBMAs in 2020 and 30 percent had no knowledge, according to a Gallup survey.[5] This lack of understanding is concerning because new plant-based meats are unique in their formulations and processing techniques– meaning products can differ in calories, saturated fat, sodium content, and levels of protein, fiber, vitamin B12, zinc, iron, and other nutrients. Plant-based meats may also contain a food allergen depending on the source of the plant proteins in the product.

[1] International Food Information Council. Consumption Trends, Preferred Names and Perceptions of Plant-Based Meat Alternatives. November 3, 2021

[2] Good Food Institute. US retail market data for the plant-based industry.

[3] Fortune. Plant-based food sales are expected to increase fivefold by 2030. August 11, 2021

[4] ResearchandMarket.com. Plant-Based Meat Market-Global Industry Analysis (2018-2020) & Growth Trends and Market Forecast (2021-2026). January 11, 2022

[5] Gallup. Four in Ten Americans Have Eaten Plant-Based Meats. January 28, 2020

 

“Plant-based meat alternatives are a popular and valued part of our food supply,” said Sally Greenberg, NCL’s Executive Director. “This is why the public needs regulatory policies that ensure the labels on these products are accurate, complete, and provide the qualifiers necessary for consumers to understand what they are purchasing.”

As the agency that regulates plant-based foods in the U.S., FDA shares this viewpoint and has sought information on a range of issues to issue draft guidance on the labeling of plant-based foods. Therefore, NCL prepared the report to articulate the consumer’s voice on PBMA labeling and lay out a blueprint for FDA and the food industry to ensure the information needs of the public are addressed. Specifically, the report identifies seven priorities for labeling, naming, and marketing plant-based meats alternatives that are in the best interest of consumers:

  1. Establish a definition for “plant-based meat alternatives” that will unite all stakeholders. Because brands define the term “plant-based” differently, FDA guidance should define what constitutes a “plant-based meat alternative” to promote consistency in labeling across the category.
  2. Ensure brand names are not deceptive. NCL’s position is it is a deceptive practice to use brand names for PBMAs that suggest a product contains meat, seafood, or eggs when none is present. Even when the label states the product contains no meat or eggs, consumers are influenced by the brand name, especially if packaging and promotional content feature pictures and iconography of animals or the type of meat.
  3. Require that labels on PBMAs are standardized and clarify the protein source. For labels of PBMAs to be transparent, the naming and labeling of PBMAs must be uniform and consistent and ensure that consumers can readily identify the protein source. Accordingly, FDA should require that all labels and advertisements for PBMAs must:
  • Use a common name that links the protein source and the form, such as “soy burger.”
  • Make clear that the product contains some animal protein in addition to plant-based proteins like soy. Qualifying terms can include “plant-based” and “made from plants.”
  • Make clear when the PBMA contains no meat. These terms can include vegan,” “meatless,” “vegetarian,” “veggie,” and “veggie-based” as well as “plant-based” and “made from plants.”
  • Place the phrase “contains no meat,” “contains no poultry,” or “contains no eggs” on the principal display panel of vegan PBMAs near the common name and in letters at least the same size and prominence as shown in the product’s common name.
  • Not use pictures, icons, or vignettes on the packaging, in marketing materials or in advertising that suggests nutrition superiority or that the product is the same as the comparable meat product.
  1. Regulate health/nutrition claims for PBMAs. Consistent with how FDA regulates the health claims allowed on traditional food products, FDA guidance must make clear that nutrition/health claims must undergo agency review and there must be significant scientific agreement that the claim is supported by available scientific evidence.
  2. Ensure website, social media, and advertising content for PBMAs conforms to what is on the product label. The guidance must make clear that FDA considers websites and social media to be an extension of the product label, meaning the claims and information that PBMA manufacturers put online must conform what FDA allows on the label.
  3. Address the nutritional composition of the PBMAs in FDA guidance. In Canada, proposed guidelines for plant-based protein foods would include nutritionally required amounts of vitamins and mineral nutrients that must be added to the PBMA product and a minimum limit of total protein content, among other requirements. While NCL supports this approach, FDA should at least recommend levels of key vitamins and nutrients in its guidance.
  4. Educate consumers about the nutritional composition of plant-based protein alternatives. It is in the public interest for FDA and the U.S. Department of Agriculture – along with nutrition societies – to conduct education programs that explain the nutritional composition of plant-based protein food products. This will allow consumers to make informed decisions based on science-based information.

About the Report

To prepare the report, NCL built on the deliberations of an online expert panel meeting – Meeting Consumers’ Needs for Modernizing Food Standards of Identity: General Principles for Naming and Labeling Plant-Based Meat Alternatives – co-hosted by NCL and the Academy of Nutrition and Dietetics (AND) in November 2021. Exploring whether new standards of identity (SOI) for PBMAs could lead to better labeling of these meat substitutes, the meeting started with a review of the U.S. market for PBMAs and featured breakout sessions where regulatory specialists, market researchers, consumer advocates and food industry leaders debated the need for a standard of identity for PBMAs and discussed consumers’ needs for education and labeling of PBMAs.

The November 2021 meeting produced consensus that there is not enough evidence to support a standard of identity for PBMAs and in fact, that a SOI could hamper innovation within this new category of plant-based foods. Yet, the meeting generated important insights on the need for consumer education about plant-based meats, a common nomenclature for describing PBMAs, and transparency in labeling so consumers will know the composition of the products they buy. Thus, when FDA announced plans to issue draft guidance on PBMAs in 2022, NCL used the deliberations from the November 2021 meeting as the foundation for developing recommendations for how FDA can ensure labels of PBMA products meet consumers’ needs. The final step was a literature review NCL conducted in March and April 2022 to add marketplace data on PBMAs and apply lessons learned from consumer research, voluntary labeling initiatives, legislation passed in different states label PBMAs, and labeling rules for PBMAs proposed or instituted in other countries.

Read the report here.

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About the National Consumers League (NCL) 

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.

 

Nancy Glick

Consumers need accurate product names and labeling of plant-based meat products

Nancy GlickBy Nancy Glick, Director of Food and Nutrition Policy

With mounting information that plant-based diets are generally better for people’s health and the environment, many consumers are giving “meatless meats” a try.

About two-thirds of Americans consumed “plant-based meat alternatives” – or PBMAs – in the past year, with 20 percent eating them at least weekly, according to an August 2021 survey from the International Food Information Council (IFIC).[1] As a result, current estimates put the market for PBMAs at $1.4 billion – up from $962 million in 2019[2] –and a Bloomberg Intelligence Report predicts a 500 percent increase in global sales of plant-based foods globally by 2030.[3]

It is easy to understand consumers’ excitement about meatless products that closely resemble the look, feel and taste of burgers, sausages, deli meat and other products made from beef, pork, chicken, eggs and seafood. Polling shows consumers’ top reason for buying these products is the perceived healthfulness of PBMAs. The most sought-after benefits consumers cite are heart health and a good source of high quality and complete protein.

Yet, the reality is that plant-based meat products vary in their formulations, nutritional content and can be high in saturated fat and sodium. These products are often packaged in the same way as their animal protein counterparts and routinely sold next to the meat section in supermarkets. Thus, consumers need clarity in labeling to ensure product names, descriptions and packaging are not misleading and consumers have the qualifying terms to make informed decisions.

As the agency that regulates plant-based foods in the US, the Food and Drug Administration shares this viewpoint. Later this year, FDA will issue draft guidance on the labeling of plant-based milks and plant-based alternatives to “animal-derived foods” (meats) under the umbrella of the agency’s Nutrition Innovation Strategy. The strategy addresses the need for FDA to modernize its regulatory approach for new categories of foods, like PBMAs, developed through the latest technologies.

In developing its draft labeling guidance, FDA has sought information on a range of issues related to labeling, including whether consumers understand terms like “milk” when used in the name of plant-based alternatives and are aware of the nutritional differences between traditional meat and dairy products and their plant-based substitutes. In response, the agency has received thousands of comments from industry groups, manufacturers, academic institutions and professional societies offering their viewpoints. However, the National Consumers League contends that the consumer’s voice must be articulated and heard. Unless the information needs of consumers are clearly defined, FDA’s goal of labeling for transparency and clarity will not be realized.

To provide the consumer perspective, especially regarding decisions about plant-based meat alternatives, in November 2021 NCL and the Academy of Nutrition and Dietetics (AND) convened a panel of experts to assess consumers’ needs for accurate naming, labeling and claims on the package of PBMAs. Comprising regulatory specialists, market researchers, consumer advocates and food industry leaders, the panel also addressed how some key principles laid out in FDA’s Nutrition Innovation Strategy – a common nomenclature, accurate naming and labeling, and elements that assure honesty and fair dealing — can be applied to improve consumer understanding, perception, and decision-making of PBMA products.

In the near future, NCL will issue a full report of the findings of the expert panel and the implications for consumer education efforts and public policy. However, the need to articulate the consumer perspective on labeling PBMAs shouldn’t wait. Therefore, NCL has translated the consensus from the expert panel into a blueprint for FDA and the food industry.

The following are the seven priorities for labeling, naming and marketing plant-based meats alternatives that are in the best interest of consumers:

  1. Establish a definition for the category of “plant-based meat alternatives” that will unite all stakeholders
    Today, many brands, companies and organizations define the term “plant-based” differently and there is not collective agreement on definition of a “meat alternative.” Since these terms represent an entire class of food products, FDA guidance should define what constitutes a “plant-based meat alternative” to promote consistency in labeling across the category.
  2. Ensure brand names are not deceptive
    NCL’s position is it is a deceptive practice to use brand names for PBMAs that suggest a product contains meat, seafood or eggs when none is present or is better/healthier than the traditional animal protein product. Even when the label states the product contains no meat or eggs, consumers are influenced by the brand name, especially if the packaging and content on the website, social media platforms and in ads shows pictures and iconography of animals or the type of meat. 
  3. Require that labels on PBMAs are standardized and clarify the protein source

For labels of PBMAs to be transparent, the naming and labeling of PBMAs must be uniform and consistent and ensure that consumers can readily identify the protein source. Accordingly, FDA should require that all labels and advertisements for PBMAs must:

  • Use a common name that links the protein source and the form, such as “soy burger.”
  • Make clear that the product contains some animal protein in addition to plant-based proteins like soy. Qualifying terms can include “plant-based” and “made from plants.”
  • Make clear when the PBMA contains no meat. These terms can include vegan,” “meatless,” “vegetarian,” “veggie,” and “veggie-based” as well as “plant-based” and “made from plants.”
  • Place the phrase “contains no meat,” “contains no poultry,” or “contains no eggs” on the principal display panel of vegan PBMAs near the common name and in letters at least the same size and prominence as shown in the product’s common name.
  • Not use pictures, icons or vignettes on the packaging, in marketing materials or in advertising that suggests nutrition superiority or that the product is the same as the comparable meat product.
  1. Regulate health/nutrition claims for PBMAs
    Consistent with how FDA regulates the health claims allowed on traditional food products, FDA must make clear in its guidance that nutrition/health claims must undergo review by the FDA through a petition process and there must be significant scientific agreement that the claim is supported by available scientific evidence.
  2. Ensure website, social media, and advertising content for PBMAs conforms to what is on the product label

The guidance must make clear that FDA considers websites and social media to be an extension of the product label, meaning the claims and information that PBMA manufacturers put online must conform what FDA allows on the label.

  1. Address the nutritional composition of the PBMAs in FDA guidance
    In Canada, regulation of PBMAs includes nutritionally required amounts of vitamins and mineral nutrients that must be added to the PBMA product and a minimum limit of total protein content, among other requirements. While NCL supports this approach, FDA should at least recommend levels of key vitamins and nutrients in its guidance and address concerns, such as allergenicity with labeling requirements to flag known allergens, such as soy.
  2. Educate consumers about the nutritional composition of plant-based protein alternatives

It is in the public interest for FDA and the US Department of Agriculture – along with nutrition societies – to conduct education programs that explain the nutritional composition of plant-based protein food products. This will allow consumers to make informed decisions based on science-based information.

Plant-based meat alternatives are a popular and valued part of our food supply. That is why the public needs regulatory policies that ensure the labels on these products are accurate, complete, and provide the qualifiers necessary for consumers to understand what they are purchasing.


[1] International Food Information Council. “Consumption Trends, Preferred Names and Perceptions of Plant-Based Meat Alternatives. November 3, 2021.

[2] Good Food Institute. US retail market data for the plant-based industry. Accessible at: https://gfi.org/marketresearch/

[3] Fortune. Plant-based food sales are expected to increase fivefold by 2030. August 11, 2021. Accessible at: https://fortune.com/2021/08/11/plant-based-food-sales-meat-dairy-alternatives-increase-by-2030/

Food insecurity among African and Hispanic American communities in America

By Nailah John, Program Associate

Millions of Americans struggle with food insecurity—defined as limited or uncertain access to sufficient, nutritious food. People experiencing severe food insecurity skip meals or go hungry because they lack financial resources to purchase food. Food insecurity is associated with harmful consequences to physical and mental health, along with adverse behavioral and academic outcomes.

With millions of Americans out of work since mid-March 2020 due to COVID-19, low-income families and communities of color, who were already at risk for food insecurity, face even greater hardship. In March and April 2020, 48 percent of African American households and 52 percent of Hispanic households experienced food insecurity, according to data published in the American Journal of Public Health. Over many decades, discriminatory policies and practices have caused African American communities to be more likely to live in poverty, face unemployment, and have fewer financial resources, like savings or property, than their white counterparts.

Food deserts, which are common in low-income areas, have contributed to the crisis of food insecurity. Food deserts are regions where people have limited access to healthy and affordable food. In these areas, people’s nutritional options are often limited to cheaper, high-calorie, and less nutritious food. In eight of the 10 counties in the U.S. with the highest food insecurity rates, more than 60 percent of the residents are African American. Associate Professor of Kinesiology and Nutrition at Northern Illinois University, Odoms-Young, said “it is really not surprising when you consider the drivers of food insecurity: income, employment. It is also an accumulation of disadvantages that happens. I don’t think people always recognize that accumulation—how disadvantages can accumulate over generations and cause those disparities in wealth.”

African American and Hispanic American populations are disproportionately enrolled in the government Supplemental Nutrition Assistance Program (SNAP). This benefits over 35 million Americans. The Biden Administration recently allocated $1 billion to the SNAP benefits distributed each month, which will increase the food stamp benefits of approximately 25 million people. Food insecurity, unfortunately, continues to be a major problem in America, exacerbated by the effects of the pandemic, from the lack of access to reduced-cost school meals to high rates of unemployment.

Access to nutritious food is essential to creating a more healthy, sustainable, and productive society. It is, therefore, crucial that we continue to advocate for African American and Hispanic communities, which are most at risk for food insecurity.

National Consumers League releases its top 10 food and nutrition policy priorities for 2021

March 23, 2021

Media contact: National Consumers League – Carol McKay, carolm@nclnet.org(412) 945-3242 or Taun Sterling, tauns@nclnet.org(202) 207-2832

Washington, DC—As the food and nutrition policy debate ramps up at the federal level, the National Consumers League (NCL) today released a 10-step action plan to address the explosion of food-related diseases in the United States and the unprecedented hunger and food safety challenges exacerbated by the COVID-19 pandemic.

Announced at a time when policymakers must confront a series of crises affecting the health and nutritional status of the American public, NCL’s action plan focuses on implementing policies that will improve food safety, reduce food insecurity, and address food waste while also removing the pervasive roadblocks that keep consumers from making more informed food and beverage choices. Due to these barriers, research studies show that Americans, on average, consume 50 percent more sodium per day than health experts recommend, more than 80 percent have dietary patterns that are low in vegetables, fruit and dairy, and only 23 percent consume amounts of saturated fat consistent with the limit of less than 10 percent of calories.[i]

“Effective policies are necessary to overcome the fragmented food supply chains, child hunger, food waste, and food safety challenges caused or amplified by the COVID-19 pandemic,”said Sally Greenberg, NCL’s Executive Director. “At the same time, the threat of food-related disease requires the sustained attention of the advocacy community. This is why NCL will intensify its education and advocacy in 2021 to advance healthier eating, improve food safety, reduce food insecurity, and elevate food waste as a consumer issue.”

Serving as the consumer voice in championing policy solutions that will have a direct impact on the American public, NCL will focus its efforts these ten priorities:

  1. Elevate portion control and balance as a consumer issue

NCL will advance the recommendations contained in the 2020-2025 Dietary Guidelines for Americans to achieve a healthy balance of food choices through education and advocacy that emphasizes portion control and ensures consumers know the recommended daily intake of calories is 2,000 per day.

  1. Reduce excess sodium in the diet

Because excess sodium in the diet can raise blood pressure, which is a major risk factor for heart disease and stroke, NCL will encourage consumers to flavor foods with herbs and spices and choose products with reduced or no salt added, thereby advancing the goal set by the Food and Drug Administration (FDA) to lower sodium intake to 2,300 milligrams (mg) per day.

  1. Improve the labeling of alternative sweeteners

NCL is supporting a Citizen’s Petition to FDA to ensure transparent labeling of novel sweeteners and has joined with other consumer groups in urging FDA to stop misleading claims, such as “No Added Sugars,” “Zero Sugar,” and “Reduced Sugars,” that imply a new product is healthier than the original without disclosing that the sugar reduction resulted from reformulation with artificial substances and sugar alcohols.

  1. Make Alcohol Facts labeling mandatory

Continuing a fight launched in 2003, NCL and other consumer, public health, medical, and nutrition organizations will urge the Treasury Department’s Bureau of Alcohol and Tobacco Tax and Trade (TTB) to issue rules requiring an easy-to-read, standardized “Alcohol Facts” label that lists the ingredients in all beer, wine, and distilled spirits products. Currently, TTB has opted for voluntary labeling, and the result is that many products remain unlabeled or carry incomplete labeling information.

  1. Require labeling of caffeine content

Because FDA only requires that food labels disclose there is added caffeine in a food or beverage, NCL will press the agency to require that all products containing caffeine be required to list the amount per serving and per container. This will make it easier for consumers to know how much caffeine they are consuming from different products so they can stay below the 400 milligrams (mg) of caffeine per day level that FDA has determined is not generally associated with dangerous side effects.

  1. Modernize food standards of identity

Because many “standards of identity” — recipes for what a food product must contain and how it is manufactured — are now 75 and even 80 years old and out-of-date, NCL supports FDA’s action plan to modernize food standards of identity. NCL is also calling attention to several food products — such as olive oil, Greek yogurt, and canned tuna — where issuing new or updated standards of identity are needed now.

  1. Revise the definition of the term “Healthy” and front of pack food labeling symbols

While supporting FDA’s decision on modifying how “low fat” will be calculated as part of the agency’s criteria for when a food can be labeled as “healthy,” NCL will press FDA to address if and how added sugars content is calculated. NCL will also encourage FDA to adopt a “Traffic Light” labeling system to depict “healthy” on the front of the package.

  1. Strengthen the food safety system

NCL will work to make improvements in the nation’s food safety system, including pressing to expand pathogen testing in meat and poultry products and to finalize FDA’s Food Traceability Proposed Rule, which would establish a standardized approach to traceability record-keeping.

  1. Reduce the amount of food waste

Every year, about 90 billion pounds of food goes uneaten in the United States, with huge environmental and food insecurity consequences.  To change this food waste crisis, NCL will raise awareness of food loss and waste and inform consumers about how they can reduce food waste in their homes and when they go out to eat.

10. Increase funding and access to federal nutrition programs

NCL will work to make permanent the 15 percent Supplemental Nutrition Assistance Program (SNAP) benefit increase now included in the American Relief Plan, while also pressing for additional funding for the National School Lunch and Breakfast Program.

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.
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Nancy Glick

2021 NCL Food Policy Priorities

Nancy GlickBy Nancy Glick, Director of Food and Nutrition Policy

With the enactment of the American Rescue Plan, the new Biden Administration will bring about important changes to overcome one of the most urgent problems caused by the COVID-19 pandemic: millions of Americans are facing hunger in the U.S. and many of them are children. According to the latest Household Pulse Survey from the Census Bureau, over 25 million people do not have enough food to eat some of the time or often.[1]

Yet, this is just one of the food-related challenges encountered during the pandemic. About 110,000 restaurants have closed permanently[2], retail food prices went up an average of 3.4 percent in 2020[3], and the amount of food waste, estimated at between 30-40 percent of the food supply before the pandemic[4], has grown exponentially. Additionally, and unrelated to the pandemic, the recently released 2020-2025 Dietary Guidelines for Americans underscores an explosion of obesity and diet-related diseases in America. Some disturbing findings are that 6 in 10 adults have one or more diet-related chronic diseases and seven percent of children and teens have been diagnosed with high blood cholesterol levels.

All these problems affect the lives of all Americans, which is why the National Consumers League (NCL) will intensify our education and advocacy in 2021 to advance healthier eating, improve food safety, reduce food insecurity, and address food waste.

We focus our efforts on where we can have the most impact, taking action to:

1. Elevate portion control and balance as a consumer issue

NCL will advance the Dietary Guidelines’ recommendation to achieve a healthy balance of food choices by emphasizing the importance of portion control and ensure consumers know the recommended daily intake of calories is 2,000 per day. We also want to encourage greater use of “My Plate,” a plan developed by the U.S. Department of Agriculture (USDA) to help consumers personalize their portions for various food groups—what and how much to eat, based on one’s age, sex, height, weight, and physical activity level.[5]

2. Reduce excess sodium in the diet

NCL is greatly concerned that Americans on average consume 50 percent more sodium per day than recommended by the Dietary Guidelines. Because this increases the risk for hypertension, heart disease and heart attacks, and stroke, we will advance the goal set by the Food and Drug Administration (FDA) to lower sodium intake to 2,300 milligrams (mg) per day and encourage consumers to flavor foods with herbs and spices instead of salt, and use the Nutrition Facts label to choose products with less sodium, reduced sodium or no salt (sodium) added.

3. Improve the labeling of alternative sweeteners

NCL applauds FDA’s decision to include “Added Sugars” on the recently updated Nutrition Facts label but we remain concerned about how novel sweeteners are labeled. Therefore, NCL is supporting a Citizen’s Petition to FDA to ensure transparent labeling of substitute sweeteners and has joined with other consumer groups in urging FDA to stop misleading claims, such as “No Added Sugars,” “Zero Sugar,” and “Reduced Sugars.” These claims imply the new product is healthier than the original, without disclosing that the sugar reduction resulted from reformulating with artificial substances and sugar alcohols.

4. Make alcohol facts labeling mandatory

Since 2003, NCL and 75 other consumer, public health, medical and nutrition organizations have pressed the federal agency that regulates alcoholic beverages—the Treasury Department’s Bureau of Alcohol and Tobacco Tax and Trade (TTB)—to issue rules requiring an easy-to-read, standardized “Alcohol Facts” label on all beer, wine, and distilled spirits products. Currently, TTB has opted for voluntary labeling and the result is that many products remain unlabeled or carry incomplete labeling information. We are not giving up! In 2021, NCL will step up the fight to ensure complete labeling information on alcoholic beverages.

5. Require labeling of caffeine content

FDA considers 400 mg of caffeine per day as the amount not generally associated with dangerous side effects. An 8-ounce cup of coffee has about 95 mg of caffeine, a 12 ounce can of Coca-Cola has 34 mg, high caffeine drinks may have 160 mg for 16-ounces. The FDA only requires food labels to disclose that there is added caffeine in the food or beverage. This makes it hard for consumers to stay within the recommended limit because they don’t know how much caffeine is in the foods and beverages they consume. For this reason, NCL strongly believes that all products containing caffeine should be required to list the amount of caffeine per serving and per container and we will push for that requirement.

  1. Modernize food standards of identity

“Standards of identity” establish recipes for what a food product must contain, how it must be proportioned, and sometimes how it must be manufactured. However, many food standards are now 75 and even 80 years old and out of date. This is why NCL supports FDA’s action plan to modernize food standards of identity, but we are also calling attention to several food products—such as olive oil, Greek yogurt, and canned tuna—where issuing new or updated standards of identity are needed now.

7. Revise the definition of the term “healthy” and front of pack food labeling symbols

Currently, a food can be labeled “healthy” if the amount customarily consumed is low in fat, low in saturated fat, contains less than 480 mg of sodium, has a limited cholesterol, a significant amount of fiber, and at least 2 additional beneficial nutrients such as vitamins A, C, D, calcium, iron, protein or potassium. This will change because FDA recently modified how low fat will be calculated. While NCL supports this step, we will press FDA to address if and how added sugar content is calculated and will encourage FDA to adopt a “Traffic Light” labeling system to depict “healthy” on the front of the package.

8. Strengthen the food safety system

NCL will work individually and as a member of the Safe Food Coalition to make improvements in the nation’s food safety system. Priorities include finalizing FDA’s Food Traceability Proposed Rule, which would establish a standardized approach to traceability recordkeeping; expanding pathogen testing in meat and poultry products; and updating safe handling instructions labels for these products.

9. Reduce the amount of food waste

Every year, about 90 billion pounds of food goes uneaten in the US, with huge environmental and food insecurity consequences. To change this food waste crisis, NCL will raise awareness of food loss and waste and inform consumers about how they can reduce food waste in their homes and when they go out to eat.

10. Increase funding and access to federal nutrition programs

NCL will work to make permanent the 15 percent Supplemental Nutrition Assistance Program (SNAP) benefits increase now included in the American Relief Plan, while also pressing for additional funding for the National School Lunch and Breakfast Program.

Conclusion: Advancing a policy agenda that ensures transparent food labeling, improves the safety and quality of the foods people eat, reduces food insecurity, and addresses food waste is essential to improving American’s lives. The stakes are high and NCL is committed to making a difference for consumers


[1] U.S. Census Bureau. Household Pulse Survey. May 20, 2020

[2] National Restaurant Association. COVID-19 Restaurant Impact Survey V. December 2, 2020

[3] U.S. Bureau of Labor Statistics. Consumer Price Index Summary. March 10, 2021

[4] Food and Drug Administration. Food Loss and Waste. February 23, 2021

[5] The National Confectioners Association “Always a Treat” consumer education campaign is one example of how portion control can be easily utilized to control calorie consumption and achieve the dietary patterns recommended in the Dietary Guidelines. As part of this campaign, leading chocolate and candy companies have pledged that half of their individually wrapped products will be available in sizes that contain 200 calories or less per pack.

Is it a meat product or not?

By Nailah John, Program Associate

My husband has a great desire for meatless products, so on my weekly grocery shopping visits, I find myself standing in the freezer aisle for minutes reading the confusing labels on these meatless products. Many of the labels illustrated on the front of the packages usually have an image of a burger or chicken nuggets and can be difficult to distinguish between actually meat products. The packaging displays verbiage like Chik, Steaklet, Well Carved, Chick N’Mix, and are placed in areas where grocery shoppers purchase regular meat products, which makes it all the easier for consumers to mistakenly purchase meatless products.

Plant-based burgers and faux-chicken nuggets are the new trend and many consumers either want to try it or have fallen in love with the product. According to a poll done by Gallup in 2020, 41 percent of adults in the U.S. have tried a plant-based meat product. The study illustrated that about half of Americans are familiar with a plant-based product. The overall takeaway? Plant-based products are in fact getting pretty big so their popularity is growing. Many consumers of plant-based products have expressed that they are cutting back on their meat consumption. Health, the environment, and animal welfare are all cited as major reasons why. With more and more Americans trying these plant-based products labeling should be precise, not misleading.

Many industry leaders continue to recommend that these products should not use wording like “vegan” or “vegetarian” because it may turn away potential customers. It is also suggested that putting meat-free options in a separate vegetarian section of the menu or in the vegetarian section of a grocery store could reduce sales. The term plant-based has been the alternative to the word vegan which is more appealing to the consumers.

However lucrative marketing buzz words may be, the wording and imaging for products should reflect what the consumer is purchasing. This wordplay and product placement tactics are being used to bamboozle consumers.

We all have a right to know what is in our food, how it is produced, and where it is from. We also have the right as consumers to demand clear labeling. It’s challenging to stand in a grocery store for 5 to 10 minutes just trying to be sure that the plant-based product we’re looking to buy is actually plant-based. The labels and imagery do not reflect this by showing chicken-like nuggets, burgers, meatballs, and other imagery that sends a false message to our minds. As a consumer, I no longer want to be confused. I want to be able to easily differentiate between real meat and plant-based meat products.

Does your baby’s food contain toxic metals?

By Nailah John, Program Associate

As a mother, I once fed my baby with baby food only to later be told that some baby foods contain toxic metals at levels that exceed what experts and governing bodies say are safe. Congressional investigators have found dangerous levels of toxic heavy metals in many popular baby food brands. The World Health Organization says that the top 10 chemicals of concern for infants and children include arsenic, lead, cadmium, and mercury.  This exposure to heavy metals in childhood is linked to permanent dips in IQ, an increased risk of future criminal activity, and damaged long-term brain function.

Some pediatricians and children’s health experts say that heavy metals are found in soil and contaminate crops grown in it. Heavy metals can also get into food during manufacturing and packaging processes. However, the amount that is allowed in baby food products exceeds the limit. The nonprofit Healthy Babies led a national investigation and found that 95 percent of baby foods tested contain toxic chemicals. Fifteen foods accounted for half the risk, with rice-based foods at the top. Making these food and lifestyle changes can help reduce toxic metal residue:

  • Choose rice-free snacks over rice-based ones. Try a frozen banana or a chilled cucumber instead of rice-based teething biscuits.
  • Opt for oatmeal over rice cereal.
  • Give tap water over fruit juice.
  • Rather than sticking strictly to baby food made from sweet potatoes and carrots (which contain higher levels of metals), opt for baby food made from other fruits and vegetables.
  • Make your own baby food by buying, washing, and blending your own fruits and vegetables.
  • Don’t get stuck in the baby food phase. Baby food is meant to be transitional, used only for a few months. Introduce your babies to sources of protein like fish—salmon, tuna, cod, whitefish, and pollock.
  • Visit the pediatrician often in the first two years of your child’s life. This can help to identify any developmental problems.
  • Limit heavy metal exposure in other ways. Heavy metals are also found in peeling or chipping paint in older homes built before 1978.
  • Don’t smoke or vape as secondhand and even thirdhand smoke (or residue from smoking on furniture or clothes) may expose children to metals like cadmium and lead.

While individuals can do their part, the most significant changes will have to come through enforced legislation and stronger regulations on baby food. According to the recent congressional report, toxic metals in tested baby food eclipse safe levels, “including results up to 91 times the arsenic level, up to 177 times the lead level, up to 69 times the cadmium level, and up to 5 times the mercury level.” The report recommended that the Food and Drug Administration require baby food manufacturers to test their finished products for toxic heavy metals and label products that contain them. One of the most powerful ways of creating change is by calling your Member of Congress and urging them to use their voice to address the issue of heavy toxic metals in baby foods. As a mother, I plan to do so and so should you.

The evolution of American alcohol policy — and what’s next

By Nailah John, Program Associate

Alcohol is consumed by billions of consumers the world over. Humans drink alcohol for many reasons, including enjoying the taste or coping with stress while others consume alcohol because of social influences. More than 85 percent of people around the world consume alcohol. America’s alcohol policy has seen many ups and downs over many decades from prohibition in the 1920s to the end of prohibition in 1933, National Minimum Drinking Age Act in 1988, the Alcohol Beverage Labeling Act 1988 (ABLA), and the continued efforts for a “Nutritional Facts Label” on all alcoholic beverages by consumer advocacy groups.

Every other consumable product on the supermarket shelves is required to have a Nutritional Facts Label. That label has a list of required information about a food’s nutrient content, such as the calories, protein, vitamins, fat, sugar, sodium, and fiber. This is critically important consumer information for guiding healthy choices.

After Prohibition In 1935, the Federal Alcohol Administration governed alcohol regulation. In 2003, the Alcohol and Tobacco Tax and Trade Bureau (TTB) was formed, and alcohol continued to be regulated by this federal agency. Since the 1970s, consumer advocacy groups have worked for a comprehensive label on all alcoholic products. In 2003, the Center for Science in the Public Interest (CSPI) and the National Consumers League made a hard push for a nutritional facts label. Manufacturers asked for voluntary labels, making the argument that putting nutrition facts on all bottled of alcohol would make consumers think that alcohol was nutritious. In 2004, TTB sided with manufacturers and issued guidelines that allowed them to list calories, carbs, protein, and fat­—but only if they wished to do so voluntarily. In 2021, NCL and other groups are recommitting ourselves to this consumer information campaign.

The Dietary Guidelines 2020-2025 lay out the existing recommendations for sugar and alcohol, which recommend moderate alcohol consumption––up to one alcoholic drink per day for women and up to two per day for men. The CDC warns that alcohol consumption is associated with a variety of short and long-term health risks: high blood pressure, various cancers, motor vehicle accidents, violence, and sexually risky behavior. The CDC guidelines also note that pregnant women should refrain from alcohol consumption and that those with certain condition should avoid alcohol. That is true as well with certain medications.

More than half—55 percent—of Americans say they have had alcohol in the past month. An estimated 14.5 million American adults age 12 and older battled an alcohol use disorder, or 5.3 percent of this population. The bottom line is that if you drink, do so in moderation per the CDC and DGAC guidelines. And join with consumer advocates fighting for a nutritional facts label to be put on all alcoholic beverages.

Consumer group: 2020-2025 Dietary Guidelines falls short on alcohol, sugar recommendations

For immediate release: January 6, 2020

Media contact: National Consumers League – Carol McKay, carolm@nclnet.org, (412) 945-3242 or Taun Sterling, tauns@nclnet.org, (202) 207-2832

Washington, DC –At a time when almost 75 percent of American adults are overweight or obese and as many as six in 10 have one or more diet-related chronic disease, such as diabetes and hypertension, the National Consumers League (NCL) is concerned that the just released 2020-2025 Dietary Guidelines for Americans do not contain clear recommendations on added sugars and alcohol consumption that can help reverse these trends.

While stressing the importance of consuming mostly nutrient-dense foods and beverages – especially fruits, vegetables, whole grains, fat-free and low-fat dairy products, and lean meats and poultry – the 2020-2025 Dietary Guidelines fall short when it comes to advice on limiting added sugars. Despite the urging of the independent Dietary Guidelines Advisory Committee to recommend that Americans reduce their consumption of added sugars to 6 percent of daily calories, the 2020-2025 guidance continues to allow for up to 10 percent. This is worrying because added sugars, which include high fructose corn syrup, maltose, sucrose, molasses, corn sweetener and fruit juice concentrates, are ubiquitous in foods and beverages and contribute only calories but no essential nutrients.

“We are greatly disappointed that the latest dietary guidelines make no progress in educating Americans about moderate drinking, despite compelling evidence of excessive alcohol use in the country,” said NCL Executive Director Sally Greenberg. “As the new Dietary Guidelines itself acknowledges, about half of the estimated 66 percent of adults who drink alcoholic beverages report binge drinking – sometimes multiple times a month. Americans need significantly more information to make responsible drinking decisions than is now contained in the 2020-2025 Dietary Guidelines.

Consumption of alcohol during pregnancy continues to be a problem in the United States. Specifically, one on ten pregnant women reported consuming alcohol with an average intake of two or more drinks on the day in question.

On a positive note, the latest guidelines define a standard “drink” as 12 fluid ounces of regular beer, 5 fluid ounces of wine, and 1.5 fluid ounces of 80-proof distilled spirits (all equaling 0.6 fluid ounces or 14 grams of pure alcohol). However, the reality is most adult Americans don’t know this and consider a “drink” to be the contents in a glass, bottle, or can.  Thus, it is challenging to follow the dietary guidelines advice to limit consumption to two drinks or less for men and one drink or less for women.

For this reason, the National Consumers League is renewing the call for the federal agency that regulates alcoholic beverages – the Treasury Department’s Alcohol and Tobacco Tax and Trade Bureau (TTB) – to mandate an easy-to-read, standardized “Alcohol Facts” label on all beer, wine and distilled spirits products on an expedited basis. Our call for alcohol labeling goes back to 2003 when NCL and 76 other organizations first petitioned TTB to require alcohol and nutrient content information on alcoholic beverage products, including the serving size, amount of alcohol (in fluid ounces or grams) per serving, number of calories per serving, and the percent of alcohol by volume.

“Unfortunately, we are still waiting for alcohol labeling and the American public is paying the price in higher rates of chronic diseases, depression, learning and memory problems, and serious injuries, such as motor vehicle accidents, falls, drownings, and burns,” said Greenberg.

According to a study published in the July 31, 2020 issue of the Morbidity and Mortality Weekly Report (MMWR), researchers at the Centers for Disease Control and Prevention (CDC) estimate an average of 93,296 deaths (255 per day) and 2.7 million years of potential life lost in the United States each year from excessive alcohol use at a cost to the economy of $249 billion in 2010 alone.

“Only with comprehensive alcohol labeling will Americans have the facts to heed the advice on alcohol consumption contained in the newly released 2020-2025 Dietary Guidelines and for the public health community to have the tools to reduce excessive drinking in a meaningful way,” said Greenberg.

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About the National Consumers League (NCL)

The National Consumers League, founded in 1899, is America’s pioneer consumer organization. Our mission is to protect and promote social and economic justice for consumers and workers in the United States and abroad. For more information, visit www.nclnet.org.