2004N-0463 Food Labeling: Prominence of Calories
FDA Comment Number : EC18
Submitter : Mrs. Rebecca Mandell Date & Time: 06/17/2005 11:06:07
Organization : Food and Nutrition Service, USDA
Category : Federal Government
Issue Areas/Comments
Food Labeling: Prominence of Calories

Any proposed changes in rulemaking may not be effective on their own; providing labeling education is absolutely essential if the food label is going to be an effective tool in weight control and management
Adding %DV for calories could prove to be beneficial to the consumer. It would give the consumers the opportunity to look at the proportional contribution of calories one particular serving of a food makes towards a daily intake of 2,000 calories. However, it is important to make sure that consumers are aware that the %DV is based on a 2,000 calorie diet, which may be lower or higher than they need.
Calories from fat? section is often misunderstood by consumers. Removing this section may eliminate consumer difficulty with having to mathematically determine the percentage. The label provides fat in gram amounts; if someone were interested in determining their calories from fat, simple multiplication could be done.
With regards to the use of calorie information on food labels, calories per serving is most likely the numeric value on the Nutrition Facts Label used most often by consumers in determining how much of a given food to eat as well as selecting which foods to eat. According to the focus groups, consumers often have a misunderstanding of what a calorie is and why it is used differently for foods than in physical activity where a calorie is an indication of time and effort.
With regards to reformulation of foods or redesign of packaging, more consumer testing would be essential. If the caloric content per package were required to be more prominently displayed on the PDP, there is a possibility that competition would increase among food products and potentially drive food manufacturers to package food into smaller units. With a handful of products on the market there has been a shift towards larger/family size packaging and if caloric content were to be displayed, there is a chance that product sales could experience repercussions as a result. Requiring changes and redesigning packaging could greatly affect consumer demand, subsequently affecting the food manufacturers and their proprietary benefit.