2004N-0456 Serving Sizes of Products that Can Reasonably be Consumed at One Eating Occasion; Updating of Reference Amounts Customarily Consumed; Approaches for Recommending Smaller Portion Sizes
FDA Comment Number : EC14
Submitter : Mrs. Rebecca Mandell Date & Time: 06/17/2005 11:06:43
Organization : Food and Nutrition Service, USDA
Category : Federal Government
Issue Areas/Comments
GENERAL
GENERAL
Food Labeling: Serving Sizes of Products That Can Reasonably Be Consumed At One Eating Occasion; Updating of Reference Amounts Customarily Consumed; Approaches for Recommending Smaller Portion Sizes

The terms serving size and serving tend to generate confusion and it would be helpful if the FDA dropped these terms and instead use a different name to indicate the measured/standardized unit of food shown on the label (currently called the Serving Size).
Serving size information on the NFP can be made easier if you use units more comprehendible by the average person. Gram amounts sometimes mean very little to the consumer. Serving sizes on NFP should be easily identifiable AND should also not be outrageously skewed from recommended servings according to the Dietary Guidelines for Americans and My Pyramid.
The number of servings on a package is just as important as caloric content or macronutrient totals. It is very misleading for a consumer to eat a cookie that claims 75 calories per serving BUT also states that one cookie is 4 servings.
Continued education is needed to educate the consumer on understanding the food labels appropriately. Consumers do not recognize the serving sizes on food labels as RACCs and consequently serving sizes should not be increased in size; there is the potential that increasing serving sizes may ultimately lead to over consumption. Some consumers already interpret the serving size as a recommendation on how much to eat rather than a standard reference size. Consumers just need to be educated on the fact that just because a food is packaged in smaller size does not mean it is a single serving.
The label should continue using widely accepted common household measures (1 cup, 1 tablespoon, 1 slice, 1 ounce) as the standard measures, however the variety of measure units used should be limited to a selected few so that comparison between food products is made easier for the consumer.
Labeling of individual packaged foods should not change to reflect one serving even if the food item can reasonably be consumed at one sitting. Food packages should not be identified as single servings based on RACCs, or any variation thereof. Consumers do not recognize the difference between actual serving sizes and RACCs.
In order to avoid consumer confusion, DGAs and label serving sizes/reference amounts listed on food products should be the same.
With regards to comparing calorie reductions between different products due to varying serving sizes, which is misleading, consumers tend to look quickly at numbers and fail to process and identify the source of the difference in calorie amounts.