Front-of-pack nutritional labelling has been extensively debated across a number of countries in recent years. This management briefing looks at the ongoing debate on this issue in the US and Australia, examining both industry and public health perspectives.


In the US, the increased scrutiny of food nutritional labelling by government agencies, principally the Food and Drug Administration (FDA), and the heightened engagement of the food industry on the issue have stemmed directly from public and political concern over health and diet, and in particular the rising prevalence of obesity in the US.

According to the Centers for Disease Control and Prevention (CDC), the obesity rate in the US currently stands at 33.8% for adults, against around 23% two decades ago, and 17% for children and adolescents. Childhood obesity rates have tripled since 1980.

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It is in this context that the Obama administration has made tackling obesity a priority, both through the First Lady’s Let’s Move campaign and heightened activity among government agencies.

The agency with primary responsibility in the area of food labelling is the Food and Drug Administration (FDA), which since 2009, when President Obama appointed Dr Margaret Hamburg as FDA Commissioner, has become more actively engaged in the FOP nutritional labelling issue.

In early 2010, the Institute of Medicine (IOM) was asked by Congress to conduct research into the issue of front-of-pack labelling, which was concluded in October 2011. This was aimed at informing future FDA action.

Industry engagement 

While the FDA has been waiting for the IOM to conclude its research, the Grocery Manufacturers Association (GMA), which represents US food producers, and the Food Marketing Institute, which represents retailers, have jointly developed a new front-of-pack labelling initiative which has now become known as Facts Up Front. The voluntary system was unveiled last year and is currently being rolled out.

While there were multiple factors behind the industry move, the primary catalyst according to the GMA’s Sean McBride was a speech Mrs Obama gave to the GMA’s Science Forum in March 2010 urging it to take steps to develop a front-of-pack labelling system. 

It should be noted that Facts Up Front is qualitatively different from Smart Choices, an earlier industry voluntary FOP labelling system which was heavily criticised by the FDA and was suspended in 2009. The latter was a front-of-pack label designed to be used selectively on products which the manufacturers deemed to be healthier. It was the criteria for selection of these products which was the primary source of controversy. 

McBride points out that Smart Choices did not cover the whole industry and was not designed to be applied to all products.

Facts Up Front on the other hand is a front-of-pack label which can be placed on any food product regardless of its nutritional profile and, as the name implies, simply places some key nutritional facts on the front of the pack.

Being “facts-based” is one of the system’s key strengths, says McBride. “It takes key information about calories, saturated fat, sodium and sugar in its base form, [and] moves those onto the front of the package in a very simple, easy-to-read, easy-to-use icon that helps consumers make informed decisions when they shop.”

The GMA claims another strength of the programme is that it has been “extensively tested” with consumers. Some social science experts may take issue with what defines extensive testing in this instance, but the industry can at least demonstrate that it has put questions to consumers about front-of-pack labelling and this research now stands as part of the growing wealth of intelligence that has been gathered across a number of markets about this subject in recent years.

GMA provided a grant to the International Food Information Council (IFIC), which is a non-governmental organisation based in Washington DC. IFIC conducted an online survey of 7,400 consumers in 2010 which informed the construction of the Facts Up Front icon. The design of the label, McBride states, “reflected the type of information and the presentation of the information” which respondents in that survey indicated they found most useful.

The Facts Up Front label details calories, along with three nutrients to limit in the diet: saturated fat, sodium and sugar. However, it can also include up to two of six nutrients which according to the US Department of Agriculture guidelines need to be encouraged in the American diet.

These nutrients, which have been found to be generally under-consumed by Americans, are potassium, fibre, protein, vitamin A, vitamin C, vitamin D, calcium and iron.

Market coverage of the Facts Up Front system 

The Facts Up Front label is being rolled out by GMA members and according to McBride is “building momentum”. He continues: “The Facts Up Front fact-based approach does have very wide support within industry. So we are moving full-steam ahead with the programme. Ultimately it’s leading to what will be a ubiquitous presence in the marketplace by the end of this year.”

How ubiquitous is a critical question. GMA says a “guidepost” is that the GMA and the FMI combined represent around 80% of all food and beverage manufacturing and retailing companies. “So it is our expectation that the ubiquity will match reasonably closely to that number,” McBride adds.

However, clearly in order to reach that 80% coverage, the organisations would have to secure 100% take-up among their members. When asked whether this was achievable, McBride said: “We expect significant participation but I would be remiss if I said we expected 100% participation.” 

When asked whether Facts Up Front could achieve 50% coverage of food products in stores, McBride said “we hope so”, adding that it was too early to say and the GMA would be making those assessments at the end of this year. “It is a voluntary programme and at the end of the day there will be some companies who decide to not participate for a variety of reasons.”

Among the reasons McBride suggests for companies deciding not to participate is that they might be using their own or a different system. However, one of the principle conclusions of the IOM research, detailed below, was that having a multiplicity of front-of-pack nutritional messaging was undesirable and caused consumer confusion.

Only recently, Wal-Mart launched a healthier products icon called Great For You. The company confirmed to just-food that it was still evaluating whether it would be using Facts Up Front on its private-label products and said it had not yet even begun trialling the system. While Great for You is not directly comparable with Facts Up Front, it is a front-of-pack icon which represents nutritional content, and under the IOM’s frame of reference that certainly puts it in the category of FOP nutritional labels. The contention by both the GMA and Wal-Mart that the two systems are complementary would be viewed by many to be in contradiction of the IOM’s recommendations.

One significant aspect of the collapse of Smart Choices is that it initiated a dialogue between industry and the FDA on FOP labelling which has continued. This may have begun rather less than positively, with Margaret Hamburg’s public chastening of Smart Choices, but it appears to have improved over time. Also, given that the FDA was concurrently looking at the same issue, keeping the FDA informed and seeking feedback was essential.

McBride says the industry heard the concerns over Smart Choices “loud and clear”, and on the Facts Up Front programme has had “extensive dialogue” and kept the different agencies informed. “We have been very cognisant and careful to construct it in compliance with all current FDA and USDA guidelines.”