NEW FDA NUTRITION LABEL
GUIDELINES FOR
FOOD MANUFACTURERS
Mandatory FDA changes to the required list of
nutrients, display of nutrition facts, daily values
and RACC serving sizes.
RL Food Testing Laboratory.com
1 Detailed Changes And How They
Affect Your Food Product
2 What This Means For Your Food
Product
3 What Your Business Should Be Doing
Now To Prepare
4 Frequently Asked Questions
1
DETAILED CHANGES AND HOW
THEY AFFECT YOUR FOOD PRODUCT
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The New Nutrition Facts Label is here!
The FDA has issued their final regulations for the updated
Nutrition Label. This is the biggest change to the label
since the nutrition facts label was introduced and required
25 years ago.
Many things have changed on the updated labels. Here
are some things to consider as you review our guide of
label changes.
The changes to the nutrition label may impact how your
food product’s nutrition will appear to consumers. It is
very important that you understand these changes and
prepare for any other marketing changes for your
product. You may need to have reformulations done.
Do not put this off. Start the process of updating
your labels now. It may take your company longer
than you think to make the switch. The sooner you
have the new label on the shelves, the better. This
change was consumer driven and your retailers will
be anxious to get it on their shelves.
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How They Affect Your Food Product
Let’s take a look at the detailed changes and how
they affect your food product
A• The most obvious of the changes is the redesign of
the label to focus more on calories and servings per
container. This includes a larger type size font for
calories and more prominent placement for calories
on the label.
PREVIOUS LABEL REDESIGNED LABEL
Nutrition Facts Nutrition Facts
A
Serving Size 1cookie (30g)
Servings Per Container 8 8 servings per container
Serving size 1 cookie (30g)
Amount Per Serving
Calories 150 Calories from Fat 90 Amount per serving B
Total Fat 10g
% Daily Value*
15 %
Calories 150
Saturated Fat 6g 30%
Total Fat 10g
% Daily Value*
13%
C
Trans Fat 0g
Cholesterol 25mg 8% Saturated Fat 6g 30%
Sodium 75mg 3% Trans Fat 0g D
Total Carbohydrate 15g 5% Cholesterol 25mg 8%
Dietary Fiber 1g 4% Sodium 75mg 3%
Sugars 10g Total Carbohydrate 15g 5% E
Protein 1g Dietary Fiber 0g 0%
Total Sugars 10g
Vitamin A
Vitamin C
4%
0%
Includes 6g Added Sugars 12% F
Protein 1g
Calcium 0%
Iron 2%
* Percent Daily Values are based on a 2,000 calorie diet.
Vitamin D 0mcg 0% G
Your daily value may be higher or lower depending on Calcium 5mg 0%
your calorie needs.
Calories: 2,000 2,500 Iron 1mg 6%
Total Fat Less than 65g 80g
Sat Fat Less than 20g 25g
Potassium 35mg 0%
Cholesterol Less than 300mg 300mg
Sodium Less than 2,400mg 2,400mg * The % Daily Value (DV) tells you how much a nutrient in
Total Carbohydrate 300g 375g a serving of food contributes to a daily diet. 2,000 calories
Dietary Fiber 25g 30g a day is used for general nutrition advice.
Calories per gram: Calories per gram:
Fat 9 • Carbohydrate 4 • Protein 4 Fat 9 • Carbohydrate 4 • Protein 4
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B• The RACCs or recommended serving sizes have also
been updated to reflect a more realistic representation
of what consumers are eating in one sitting. For
example, a pint of ice cream will now be declared as 3
servings instead of 4 servings per container.
C• The Daily Values, or DVs, have been updated. Some of
these include DVs for sodium and fiber. DVs are the
nutrient reference values based on age groups that are
used to calculate the percent DV that is shown on
nutrition labels.
D• Sugars that do not occur naturally in food but are added
by the manufacturer must now be declared as a
required nutrient under the new section for Added
Sugars. In addition, a percent DV of 50g of sugar has
been established for adults, and a list of added sugars
has been provided by the FDA.
E• Dietary Fiber has been defined as a non-digestible
carbohydrate. Fiber that is beneficial to human health
may be reported on the label.
F• Vitamin A & C are no longer required and have been
replaced with Vitamin D and Potassium. This change is
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being made as a result of studies showing Americans
are not getting enough of Vitamin D & Potassium, so
they are now being added as new mandatory nutrients.
G• The foot note table has been removed and a statement
has been added to explain what DVs mean.
A dual column label will DUAL COLUMN LABEL
be required for some Nutrition Facts
2 servings per container
packages that can be Serving size 1 cup (255g)
consumed in one sitting Per serving Per container
Calories 220 440
or multiple sittings. % DV* % DV*
Total Fat 5g 6% 10g 13%
This dual column label Saturated Fat
Trans Fat
2g
0g
10% 4g
0g
20%
is required for packages Cholesterol
Sodium
15mg
240mg
5% 30mg
10% 480mg
10%
21%
Total Carb. 35g 13% 70g 25%
that contain between 200 Dietary Fiber 6g 21% 12g 43%
Total Sugars 7g 14g
to 300% of the standard Incl. Added Sugars 4g 8% 8g 16%
Protein 9g 18g
serving size. For example, Vitamin D 5mcg 25% 10mcg 50%
Calcium 200mg 15% 400mg 30%
a 3oz bag of chips would Iron 1mg 6% 2mg 10%
Potassium 470mg 10% 940mg 20%
be required to have a dual * The % Daily Value (DV) tells you how much a nutrient in a serving of
food contributes to a daily diet. 2,000 calories a day is used for general
nutrition advice.
column label.
The compliance date is July 26th, 2018. However, food
manufacturers with less than $10 million in annual sale
will have one additional year to comply.
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2
WHAT THIS MEANS FOR YOUR
FOOD PRODUCTS
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What This Means For Your Food Product
• Many of these changes may impact how your food
product’s nutrition will appear to consumers. For
example, a larger serving size may increase your
calories displayed. The new fiber definitions may
lower your fiber declaration. The new added sugars
declaration may highlight undesired nutrients.
• Food manufacturers may want to reformulate some of
their products to better position how their products will
appear to consumers.
• Detailed record keeping will now be required for certain
nutrients because there are no analytical methods
currently available for some of these nutrients. Some
examples of these nutrients are Added Sugars and
Dietary Fiber. The FDA is requiring these record must
be kept by the manufacturer for at least two years.
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3
WHAT YOUR BUSINESS SHOULD
BE DOING NOW TO PREPARE
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What Your Business Should Be Doing Now
Perhaps one of the biggest mistakes a food manufacturer
can make is to wait! Take a look at the three steps we
recommend you take to be ready for the new label:
1. Request Nutrition Analysis from your ingredient suppliers
If you are getting your labels via database analysis, then
you may have to get the newly required nutrients, such
as Added Sugars, Potassium and Vitamin D from the
manufacturers of your ingredients. We may need this in
order to update this information in the database when
we do your analysis. Use the RL Food Testing Ingredient
Analysis Request form to request your ingredient
manufacturers provide the missing components of their
existing nutrition labels. We have created a form to
make it easy to send to the food manufacturers and you
can find it on our website by clicking here:
Request for Nutrition Analysis
we also have a copy at the end of this booklet.
2. Contact your retail customer to determine when they are
going to require compliance with the new label format
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The grocery chains and independent stores will likely
want to accelerate the implementation of the label
change and that means vendors who are “ready to go”
with the new format will be in a better position to get on
the shelf versus those who put off making this change.
3. Contact RL Food Testing to see what is involved in
bringing your nutrition label up to compliance
Whether you are an existing RL Food Testing customer
or new to our family, get started right now and give us a
call. We will take a look at your food product and be
able to tell you how these new changes will impact your
labeling. We will be able to advise you about your
product’s labeling requirements and help you determine
if your serving size has changed and if you are required
to use the dual column label, among other required
changes.
The answers we can provide will give you great insight
as to whether or not you want to consider a
reformulation, or a change to health claims made on
the front of your label.
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Our consultative approach will help plan and forecast
the process for transitioning to the new label according
to your inventory. Regardless, there will be a lot of
planning involved. Begin now and give us a call. This
is a very exciting time for all of us in the food business.
Our entire team at RL Food Testing is here to help our
customers navigate through this major change. We
hope to hear from you soon! Call us today for a free
consultation and personalized roadmap to compliance
for your business 877.753.6631
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4
FREQUENTLY ASKED QUESTIONS
FREQUENTLY ASKED QUESTIONS ABOUT
THE NEW NUTRITION LABEL CHANGE
1. Are these changes what we expected to see? Any surprises?
• We have been closely following these pending changes since the initialization of
the nutrition initiative by Michelle Obama.
• The final regulations seem to be in line with what was expected in the industry -
including Added Sugars. Even though Added Sugars received the majority of the
push back, we expected that it would indeed be included in the final ruling.
2. What will the impact be for new product development and product formulation?
• The impact on product development will be on two fronts; the ingredient
manufacturers and the finished goods food manufacturers.
• Ingredient companies (think of mayonnaise, corn syrup, any additive ingredients) –
will have to provide the new nutrients required in labeling, such as Added Sugars,
Potassium and Vitamin D - things they were not required to do prior to this
announcement.
• The finished goods food manufacturers will need to partner with their ingredient
vendors to get additional information about their sub ingredients so it can be
supplied to us as part of a recipe submittal package.
• Additionally, the food manufacturers will need to be more realistic in their serving
size statements that reflect an actual serving size versus a size that would have
allowed them to feature a smaller calorie count per serving. Sugary foods and
high calorie foods will probably see the biggest change in how their final product
looks on the new nutrition fact label.
• From a product development standpoint, we would imagine there will be more
collaboration with nutritionists and food scientists to develop lower calorie,
“healthier” food ingredient options to enhance flavors more naturally.
3. How will companies with well-established products and brands approach the new
label changes? Will they reformulate?
• How will companies with well-established products and brands approach the new
label changes? Will they reformulate?
• From a marketing perspective, food manufacturers will need to review current
nutrition and health claims to determine if there needs to be some reformulation to
support these claims.
• Also, reformulating some recipes may be required to allow the new serving sizes to
reflect a more attractive calorie count and added sugar disclosure
• We see indications that the grocery industry may see this as being a critical piece
of information for their customers and will take a stand to push their vendors
toward the new label faster than the FDA requirement. This may make larger
companies comply immediately to be competitive with other food manufacturers,
rather than wait out the two years until the July 26, 2018 compliance date.
Likewise, smaller manufacturers will likely change to the new format prior to their
extended grace period of an additional year given to manufacturers with less than
$10 million in annual sales.
• The challenge for them, and for us, is to get the additional nutrition information
needed in sub ingredients to generate the revised nutrition fact label
4. Given your job and what your company does, how do you see the next two years
playing out (until compliance starts kicking in)?
• As I mentioned before, we believe the grocery chains will drive a lot of the
compliance forward– faster than the provided compliance timeframe.
• We anticipate some delay in receiving the updated nutritional values for the new
required nutrients, such as Added Sugars, from the manufacturers of food
products used for ingredients. These values are not required on the current
nutrition label and so might not be readily available to our customers to update
their labels. Our software provider, ESHA, has confirmed that the database has
been updated with Added Sugars for some ingredients, including foods that meet
the definition of Added Sugar by the FDA like a syrup, as well as other foods that
do not contain sugar. It will, however, take some time for the data to be updated
for foods with a combination of added and naturally occurring sugars.
• We have a pledge to help our customers get their products ready for retail sales by
meeting FDA guidelines. We anticipated that this would raise a lot of questions
and we are already fielding questions from customers about timing and
compliance issues. We have been sending out periodic newsletter
announcements when we received new information from the FDA website and
bulletins.
• We expect our business to be impacted favorably and look forward to helping the
larger food manufacturers with overflow label development (they do most of their
label work internally) as well as helping our small to medium size manufacturers
that represent the largest segment of food producers in America.
5. Ultimately, do you think these changes will drive behavior change among
consumers?
• The FDA has a substantial amount of research supporting their final regulations on
the new nutrition facts label. From a scientific stand point, these changes will
show consumers what they need to know to make informed, healthier choices.
• We believe the nutrition initiative is a good indication that consumers are asking
for this type of information to be accurate and available – that is what is driving
the change so, yes, we do think it will modify consumer behavior.
• However, at the end of the day, we all like a little something sweet to snack on!
Request for Nutrition Analysis
I am a current customer and I am very satisfied with your product. To be in
compliance with updated FDA Regulations related to Nutrition Analysis, I am
requesting updated Information as it pertains to the nutritional analysis of the
ingredient I use in my recipe.
Please provide complete specification sheets or a 100 gram report to include the
nutrients listed below:
• Calories
• Total Fat
• Saturated Fat
• Trans Fat
• Cholesterol
• Sodium
• Total Carbohydrates
• *Dietary Fiber-Dietary Fiber has been redefined in the New FDA Nutrition Facts
Labeling regulations.
• Sugars: *Added Sugars
• Protein
- *Potassium
- *Vitamin D
• Iron
• Calcium
*Newly required
Please reference the following websites for details on my request:
https://www.federalregister.gov/articles/2016/05/27/2016-11867/food-labeling-
revision-of-the-nutrition-and-supplement-facts-labels#p-2928
https://www.federalregister.gov/articles/2016/05/27/2016-11867/food-labeling-
revision-of-the-nutrition-and-supplement-facts-labels#p-2928
Thank You
