Paper Coauthors:
Charlie Oster, Majoring in Physics with Certificates in Entrepreneurship and Engineering for Energy Sustainability (Junior)
Alex Eby, Majoring Biology with a Certificate in Global Health (Senior)
Kyle Colburn, Majoring in Geoscience with a Certificate in Environmental Studies (Senior)

| Abstract | Overarching Introduction and Literature Review | Annotated Bibliography | Materials and Methods | Results and Discussion | Limitations | Conclusions | Citations |

---

The FDA has come to us as a task force to conduct research on the best way to improve their food labeling requirements in a bipartisan and exhaustive study. We have been instructed to conduct research that will broadly improve food labels and will increase consumer engagement in their food choices. Through background data collection, we were able to gauge the current state of food labeling practices from a nutritional, environmental, and economic standing. From this we conducted surveys and interviews with professionals in their respective fields to determine necessary and possible changes to current food labeling practices. Our results showed a need for a standardization of serving sizes in "like" products, dual labeling practices, a greater emphasis on how nutritional labels are relatable to children, a basic environmental impact label focusing on water, carbon, and nitrogen, and greater cooperation between the FDA and various groups involved with labeling certifications.

---

Overarching Introduction and Literature Review

In lieu of the task we have been presented, and combined with the understanding of the bureaucratic and often confusing nature of the FDA's practices, we have decided to split this project into three sub-projects, each corresponding to a pillar of sustainability. These three sub-topics will be:   

Nutrition:

The concept of food labels was derived from a health standpoint. Providing accurate and necessary nutritional facts to consumers for the foods that they purchase. The Nutritional Labeling and Education Act (NLEA) of 1990 provided regulations over what requirements are mandated by the FDA to be on food. However, a quarter of a century later the near epidemic levels of obesity, both in the United States and others is at an all-time high. Improper diet can lead to cardiovascular diseases, diabetes and certain types of cancer. When consumers fully understand, and can comprehend the components of a nutrition label they will most likely improve their eating habits.

Food labels that are pragmatic in accessibility and comprehensibility would not only have a dramatic effect on the health of people within a given country but also have a significant economic benefit. Aggregate adult medical expenditure attributable to obesity in 1998 has been estimated to range between $26.8 and $47.5 billion (Finkelstein, Fiebelkorn, and Wang, 2003). In May of 2016, modifications to traditional nutrition labels were made by the FDA. Three major changes were made: refreshed design, reflects updates information about nutrition science and updates serving sizes and labeling requirements for certain sizes (FDA). Although these adjustments are beneficial many feel that these are minor changes in the face of growing obesity rates and health concerns attributed to poor eating habits.

Updated Nutrition Label (right) as per the Food Safety and Modernization Act

With this information, we are interested in investigating how to make food labels as efficient and effective as possible. The main labeling concerns that will be addressed:   

Environmental:

Our literature review allowed us to gather data regarding consumer behavior and perspective on environmental issues along with how they view and purchase organic products. Different environmental impact label examples combined with the relationship between organics and consumers influenced the direction of this study by telling us which questions needed to be asked of professionals in the field and what the concerns are of consumers when it comes to labeling.

Food labeling practices and improvements have had a significant impact on consumer education and their choices over the years; however, they have primarily been for nutritional purposes. Aspects that can easily go overlooked are the environmental issues associated with food production. Overall, environmental labels do exist; however, there is no well-known standardized label when it comes to defining the sustainability or footprint of a food product. Environmental concern is often expressed at a general level but when it comes down to the product level, it frequently diminishes. A goal of this portion of our study is to assess the current environmental labeling practices and determine if there are ways to incorporate them to educate consumers on the impacts of different food systems and influence them at the product level to have a more sustainable consumption. Many environmental issues do not affect consumers in a direct or immediate manner, meaning it is more difficult for people to connect with them and change their consumption habits. It is also difficult for people who want to have a more sustainably consuming lifestyle but do not know or realize the different environmental impacts of each product. Having labels that are easy to understand would allow consumers to quickly quantify and measure their environmental footprint while enhancing consumer education of various environmental issues. Due to the feasibility of this project, this study focuses solely on impact labels containing carbon, nitrogen, and water footprints, with four different labels presenting an array of detail and content designed by a study from Leach et al. (2016). Using the designs from this study, as opposed to creating our own, allowed us to focus primarily on the consumer attitude and demand for them.

Four Example "Environmental Impact" Label Choices for our Interview and Consumer Survey (Leach et al., 2016)

Entrepreneurial:

Historically, the FDA and businesses have often pushed back with one another, attempting to maintain a fair level of oversight and regulation without creating a complex and unfair barrier to businesses. Two important things to keep in mind with food labeling regulation is that small, entrepreneurial businesses are the ones historically most negatively affected, due to their lack of resources in comparison to other big players. Sadly, these entrepreneurial ventures are crucial to a healthy business ecosystem. The second important thing to keep in mind is that many NGO's, interest groups, and outside organizations are in charge of establishing the rules when it comes to various food label certifications. The FDA works in accordance with these groups, but does not have authority over them. Food businesspersons and entrepreneurs have a lot of complex factors in play when they make labeling decisions, and the answer for improvement is not always simple.


Based off of our preliminary research, we will attempt to answer the question, "In the context of nutritional, environmental, and economic factors, should current food labeling practices be changed? If so, how through what mechanisms?"

It is our hypothesis that "Given a more modern understanding of the complexity of food systems, and their various effects on social, nutritional, environmental, and economic factors, we believe changes are needed to our current food labeling practices."

---

Annotated Bibliography

---

Materials and Methods

The methodology in which each specific sub-topic was individualized and framed in the most effective means of addressing specific concerns within each subtopic.

Nutrition:

The methodology for assessing this hypothesis is to interview health professionals, nutritional scientist and pediatricians to address the current standard of nutrition labeling as well as primary sources. While comparing labeling standards in other countries along with their health and obesity rates.Interviews were conducted both over the phone and in the form of a written questionnaire.

Interview Questions:   

Interviewees:   

Environmental:

Secondary research was first conducted on current environmental labeling practices and trends, followed by an interview with a professional in the organics industry and a consumer survey. Through our findings, we will compare an economic/business perspective with that of the average consumer once introduced to environmental impact labels.

Questions that were asked in the interview include:   

Other questions included in the consumer survey include:   

Entrepreneurial:

From an economic standpoint, the methodology used to evaluate the current climate of the relationship between the FDA and business was first through background research of the FDA's website, various articles, literature, and sources. From this I was able to formulate a survey that would effectively "test" real world food business persons and entrepreneurs to gauge how well these resources were known and available to them, and would allow them to offer a brief chance to comment on the FDA. Beyond this I was able to conduct one in-person interview with a local food business person to better gain insight into the relationship of a food business and the FDA.

Here is a sampling of the survey questions:   

---

Results and Discussion

The United States Food and Drug Administration has taken necessary steps to improve the quality and visibility of nutrition labels. However, through questionnaires, interviews and further research, three issues have not been sufficiently addressed: dual-labeling requirements, segregated children's nutritional facts and promoting food label literacy.

Duel-labeling is the practice of having a front, condensed nutritional label, consisting of the most pertinent nutritional facts that should be considered when a consumer purchases food. The practice is suggested by the FDA but is currently not a requirement. The effectiveness of food label relies on easy access to clear, concise and understandable information. Through interviewing nutritional scientist, it became apparent that effective food labels have the potential to dramatically benefit the health of our country, however even when food labels are used periodically the average consumer is not aware of what certain parts of the label mean in term of their health. Current Front of the Package Labeling takes the most important information and places it on the bottom corner of the front of a product. According to Dr. Vicki Oster and Dr. David Miller, if a consumer is going to take the most basic information into account when deciding on food purchase they should focuses on serving size, servings per container and calories per serving. Therefore, it is suggested that the FDA requires front of the package labels on all products. This might seem like an undo burned for food producers and marketers, however with current preventable health problems costing the United States billions of dollars, it is a necessary and crucial step to promote healthier eating. The requirements for the Front of the Package Label would be as follows:   

Recommended Front-of-Package Dual Label

The second change suggested to food labeling is age segregated nutritional facts. The daily recommended number of calories a child should consume is not the same as for adults. All four interviewees agreed that there are no clear regulations on nutritional labeling when it comes to children and adolescents. Food labels are made based off a 2,000-calorie daily diet, the recommended amount for adults. However, when it comes to children their caloric intake is based on age, gender and level of activeness. Dr. Miller suggested at the minimum,"bigger print that this is based on 2000 cal/ day adult diet, there are differences for pediatrics and adolescents." This would draw attention to parents that these dietary facts are not directly translatable to children between the ages of 5-12. Children also need different amounts of certain food components and nutrients, for example calcium and iron. Therefore, it is suggested that the FDA requires that the 2,000 calories per day footnote is enlarged and that components on food labels that significantly differ for children would appear with an asterisk sign and footnoted that this is not applicable to nutritional recommendations for children between the ages of 5-12. In conjunction, the FDA should promote educating children in public elementary and middle schools on how to property use and apply nutrition labels.

Recommended Highlights to the Back Label, for Pediatric Concerns

Studies have shown that there is a general lack of knowledge when it comes to defining organic. Given that organic labels are still relatively new in terms of food production and despite the general lack of complete understanding and price increase, organic products have been very successful. When talking with a professional in the organic industry, a dairy production manager, about the reason consumers buy organic, she believed part of it was due simply to the idea. Many people have taken part in the organic movement by eating healthier and supporting local farmers and communities. Within the organic movement, many also share similar attitudes about protecting the environment. Organic farming is associated with environmental benefits as well. However, with the current organic label, there are no requirements associated with environmental issues. She also stated that, although organic companies attempt to address different environmental aspects, it has often shown to not pay off due the limited and valuable marketing space.

When asked about her thoughts on environmental and sustainability labeling, she admitted she had not thought about it in depth, and initially wasn't entirely sure what the purpose of this project was. When asked her thoughts on the four hypothetically defined environmental impact labels listed above (Leach et al., 2016), her first reaction was cautious, admitting it took a while to understand what she was looking at. Out of instinct and familiarity, she chose model C as most appealing. The label is very similar to the existing US FDA nutritional label as the footprint results are simply added to the bottom.

Recommended Change to the Back Label for Environmental Concerns

The leading choice between the surveyed consumers was also model C. Many of their comments aligned with those of the professional in the organic industry, stating that it is most similar to what they are used to seeing. Many people are comfortable and understand the current nutritional label; introducing a new form of labeling with content not everyone is familiar with will likely not be successful.

Overall, despite her preferences in label models, the professional in the dairy industry stated it opened up her perspective on how to look at food labels and was intrigued as to what and how other types of information can be presented to the consumer in the form of a label. A common theme with labeling in general is the consumer dissatisfaction with an oversaturation of labels that are confusing and difficult to understand. Environmental impact labels are not something people have encountered before, which makes getting used to and understanding them a priority; a simple addition to the current nutritional label could be the beginning of an expansion of future environmental labels.

An obvious difficulty in having this data on labels is how it is measured. There are numerous studies that have calculated the environmental footprint on a variety of food systems; the FDA does not have to be responsible for conducting the studies as outside sourcing for this information may be the best option. Even if it may not initially help with individual brands, it would give enough information to consumers to guide their overall decisions on what to buy and what not to buy. With growing anthropogenic pollution and consumer awareness of environmental issues (which is explained and expanded on later in the study), people have the right to make decisions based off labels to live more sustainable lifestyles. This study proves, despite the initial confusion or unfamiliarity, there is a demand for labels that include information on the environmental impact of a food product.

It is apparent that a thorough exploration of the FDA's website will turn up several critical resources for business owners and entrepreneurs in relation to food labeling. These resources include:  

• A small business guide to the FDA
• Overall labeling requirements
• Tabs on qualified health and nutritional label claims
• Information on the Food Safety and Modernization Act
• Programs to better understand food labeling requirements
• Information on food allergens and recommendations on how they should be labelled
• Some basic environmental terms and considerations within labels
• Current newsletters on various aspects of food labeling
• Various other resources

These resources are quite helpful for gathering a basic understanding of food labeling expectations and opportunities from a rudimentary standpoint, but diving deeper into the documentation obviously lends itself to further legal jargon and confusion.This combined with a confusing threading of the articles and resources made the FDA's website not intuitive in my experiences searching for information.

I was able to gather 5 respondents on my survey from local food companies and startups in Madison WI. All the respondents worked with companies with less than 10 full time employees. Examining the results from the second half of the survey showed that despite the fact the respondents of the survey ranked themselves fairly highly in terms of their understanding of labeling certifications outside of the FDA (an average score of 7.2/10), they gave mixed reviews on the FDA's connection with food business persons and entrepreneurs (5.0/10), mixed reviews of their own understanding of the FDA's general food labeling requirements (6.6/10), and poor reviews on the ease of navigation of the FDA's website (3.4/10).

Entrepreneurial Survey Question Results

Entrepreneurial Survey Question Results

Entrepreneurial Survey Question Results

Entrepreneurial Survey Question Results

This points to a conclusion that the outside labeling certification groups have more success in transmitting a clear and simple message for their certifications than the FDA does in transmitting its labeling requirements. The reasoning for this is not certain, but it may have to do with the fact these outside groups tend to handle a single subject matter as specialists, or that they shed the "bureaucratic" shell that engulfs the FDA, or that these groups are more fueled by grassroots movements, lead by more consumer demand which business persons hope to tap into.

In the interview, Tim Flores pointed to this fact, arguing that as important as the FDA is in oversight, there is a group effort between the FDA and outside groups for most of the labeling certifications. The passion of these groups is an easy way for business persons to gauge the current market demand from consumers. Due to this, Tim Flores expressed a healthy skepticism for broad, sweeping labeling mandates. Rather he expressed his belief that the strongest labeling changes will come from grassroots movements and groups pushing companies to be honest in their labeling. This fact is paralleled in Debra Strauss' An Analysis of the FDA Food Safety Modernization Act: Protection for Consumers and Boon for Business. Where she argues that the greatest success of the FSMA was the consumer demand behind it. This pushed not only politicians to want to act, but for companies to want to comply.

One other point raised in data collection were standardizing serving sizes on packages of "like" products. Tim Flores mentioned this as a quick way to help businesses compete more fairly, and to allow consumers to better compare similar products. The current status of allowing companies to pick their own serving sizes was too manipulative, said Tim. He did bring the point that qualify "like" products would be an extremely challenging task, but argued that that did not mean an effort to do so should not be in place.

Understanding the ways that business persons and entrepreneurs think is the best way to bring the changes we want to see in the nutritional and environmental labeling practices to fruition with as little resistance as possible. Understanding that these business persons appear to appreciate and understand outside interest groups better leads one to believe that changes stemming from these groups, which in turn come from consumer and grassroots efforts, will bring the best chance of change. The biggest recommendation for the FDA from an entrepreneurial standpoint is to better understand how these business persons think, and to respect that. One powerful way the FDA can show this is to respect the authority of outside certifications from interest groups. The FDA can do this by allowing these groups to work directly with businesses and simple work as the authority over the enforcement of making sure food labeled follows these outside rules. The FDA can even work to promote these certifications by connecting new food companies to them. These label certifications allow food companies to better market their products truthfully, and the FDA must recognize this.

With all this in mind, we are now ready to offer our recommendation for a new food label. Based on the social findings in our entrepreneurial survey and interview, as well as other research, we believe these new requirements would have the best chance of success if the FDA allows ample time for food businesses to adapt to this change, particularly small businesses needing time to adapt to the financial implications, as well as allowing outside organizations to work in the environmental calculations needed for this new labels. This will help businesses feel more connected to their label, less mandated by bureaucratic interests, and provide more jobs in several competing outside companies.

The most important part of the potential success of our recommended labeling change lies in a realistic consumer interest in the change. From a nutritional standpoint, a 2012 Gallup poll shows US citizens are more concerned about obesity than either alcohol or cigarettes, and rank government action to combat obesity as more important than government action combating alcohol or cigarette use.

Poll of Societal Concerns

Poll of Governmental Action Necessity for Societal Concerns

From an environmental concern, As can be seen below in a 2016 gallup poll, US concern over global climate change has been rising over the last eight years, with little evidence that this will slow anytime soon. Combined with a 2015 pew research poll showing major concern about needed policy/behavior change, we conclude consumer demand for an environmental food label (where there is none currently) is present.

Poll of Americans' Concern over Global Warming

Poll of Opinion of Necessity of Lifestyle,Policy Change

With what seems to be a proper consumer demand in place, we now come to our final label recommendation for the FDA to implement. As can be seen below, this new label combines the FSMA current label mandate with our findings in both a nutritional and environmental sense. The nutritional calories and serving sizes are now bolded and standardized for like products, for better consumer understanding. Areas of nutritional information that vary for children ages 5-12 are marked for better awareness of parents and guardians, and a basic carbon, nitrogen, and water footprint are placed below, per recommendations of of environmental survey.

Final Recommended Front Label

Final Recommended Back Label

---

There were academic limitations to this study. Due to the small number of interviews conducted and limited demographic of those that were interviewed, it would be a necessity to broaden the depth and breathe of those interviewed to obtain an accurate analysis of the changes that we have suggested. This would include, but is not limited to: different types of physicians, politicians, larger corporations, and individuals responsible for other countries labeling practices as a means of comparison.

In conjunction, there are practical limitations to our findings. The first being the cost of implementation. We were not able to conduct a cost analysis of the application of changing the requirements of nutritional labels or adding the information for the environmental impact labels. Evaluating cost for both business and the federal government would add significantly to this study. The lack of a detailed timeline and customer opinion on changes to nutritional labels were also practical limitations. Some of the suggested changes had not been scrutinized by research studies on how customers would react. Having a large data sample of consumer opinion on the recommended changes would add greatly to our findings.

Although there were limitations to the study's findings, the results underline an important discrepancy in current labeling practices and those that would have the most impact in terms of nutrition, the environment and businesses. The findings are substantiated though both primary research and through interviewing professions. These limitations do not reflect the value of the findings but rather the necessity for further investigation and analysis into labeling practices in the United States.

---

Conclusions

Nutrition Labels are unique in the sense that they are exposed to 100's of millions of people in the United States. Small changes to the nutrition facts on product labels might seem like an insignificant difference, however the sum of millions of people making more informed nutrition decision can have large effects on the health of our country. The small yet impactful nutritional recommended changes are summarized below:   

These changes will obviously need to be considered in further beta testing, and we recommend the FDA use the labels we have presented in further study to gauge their effectiveness. It is important to scale these changes based on business size as to not strain small businesses, and to allow ample time so that consumers and businesses may properly change and understand these practices. Our logic behind making these choices is based off of four main points in our study, which are experts opinion, consumer motivations (with high levels of demand for policy and behavior change in regards to climate change and obesity), successful label change precedent (looking at the ways the FSMA was implemented), and topical research.

This study did have limitations, being mainly the limited size and scope of our expert opinions, and potential practical limitations in the realistic implementation of these changes. These limitations, however, do not discredit the findings of this study, but rather allow room for further study and improvement of these recommendations we have made. These recommendations should only act as a base case, and do not represent all that is possible of food labeling under the FDA.

---

Citations