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The Plodding 3-Year Process To Redesign The FDA’s Nutrition Label

Source image: camaieu via Shutterstock

At first glance, the new FDA Nutrition Facts label, introduced by Michelle Obama in May, doesn’t look terribly different from what we’ve had since 1994. The calories are bigger and bolder. The serving sizes are a bit clearer. And for the first time, food manufacturers are required to list added sugars, offering some transparency to one of the most unhealthy additives in our processed foods.

But it still largely resembles the old label we all know—which may be surprising given that the FDA spent three years on the overhaul and people don’t understand that label all that well to begin with. Obesity is one of the largest public health problems in the United States. Research has shown that the old Nutrition Facts label is "relatively ineffective" compared with simpler labels at encouraging people to make healthy choices. Why didn't the FDA release a more radical redesign?

"There are a lot of things any good designer would be able to say, ‘why [didn’t] we do this or that?’" says Kevin Grady, currently executive creative officer at Siegel+Gale, who led the project as an independent contractor. "And unfortunately, it’s not as simple as that."

Indeed, the new FDA label is a lesson in what happens when politics design the world.


The Politics

Working for the FDA is to face scrutiny by three groups: the FDA itself, the public, and, of course, the powerful food lobbyists who were benefitting from the old labels, which had dubious portion sizes that could mask large amounts of saturated fat. "This [project] was going on for years, the nuance of the way everything was shown was up for debate and discussion," says Grady.


This scrutiny is largely by design. The FDA has to propose changes to their policies and labeling to the public (which includes the food industry). Then they wait for several months while people complain. Then, in an absurdist bit of design-by-committee, the FDA reads every single one of these comments. In the final statement on the design, you can see them list and respond to the most popular critiques—though don't expect it to clarify much about the FDA's decision process.

Keeping What Worked

When he signed onto the project three years ago—invited back to work with the FDA after developing its anti-tobacco Truth campaign—Grady was given carte blanche by the FDA to rethink the standard label from the ground up. It would still need to contain the same basic information—daily recommendations of fat, and so on—but it could be presented in any way, Grady imagined. New fonts. Color. Infographics. It was all on the table.

But Grady quickly realized that the label’s context mattered a lot. Nutrition facts are placed on packages that are already bright and laden with images. As compelling as infographic nutrition labels may be, using label imagery to compete with product imagery would be a pointless fight. Helvetica, a typeface designed for clarity and the one that appeared on the previous label, made sense to keep.

"We reviewed a lot of things. In the end, there was an awful lot about the iconic original label that is working and has worked," Grady says. The FDA argues that the label has incredible consumer recognition and consumers already understand which nutrients (like saturated fat and cholesterol) that they should limit. It’s the sort of data they have from both focus group testing—the only testing the FDA told me it performed on the label—and general public feedback. "My recommendation was to stay fairly close to that but to create more of a visual hierarchy for your eye to go through, so you don’t need a magnifying lens to read the information."


Changing What Didn’t Work

On the top of that hierarchy was calories. The FDA had decided that calories were the most important bit of information to push, so Grady made it the biggest.

"You already know, obesity and overweight—that makes up almost two-thirds of the population. That was definitely something we kept in mind being a public health agency. One thing we wanted to stress was calories and serving size. No matter what you’re eating, with excess calories, that’s promoting weight gain," says Claudine Kavanaugh, senior advisor for nutrition and policy, FDA Foods and Veterinary Medicine. "If you look at the original label, calories are in a really small font. It’s generally like the rest of the label. We wanted to make that pop more."

From an aesthetics standpoint, the calories look a bit odd, but Grady was comfortable with what he calls "exaggeration" of the design, taking an idea, like enlarging a word to make it more noticeable, to extremes for the busy context of shopping. "The way something looks is very important to me. But clearly with something like this, it was all about usability," he says. "If you’re walking in a supermarket, and you have a baby crying, and you’re trying to figure out how many calories are in it. You see that now."

Negotiating Where Needed

Serving sizes (which now more accurately reflect what people actually eat, thanks to the FDA’s previous efforts), have been bolded as well. In Grady’s earlier draft of the label, which Michelle Obama showed off in 2014, he’d moved the serving size south, so you’d see the portion size directly next to the calorie count. He found it clearer, but for whatever reason, this idea didn’t make the final cut.

"We got a lot of comments back on that," says Kavanaugh. "A lot of comments were that it was repetitive. If you look above you see 'two-third cup' and on the next line you see 'two-third cup.'" At least one of those comments was from the Grocery Manufacturers Association, which represents food and beverage companies. The GMA recommended serving size only be presented once "to further conserve label space."

So instead, the serving size stayed put, but it was bolded.

The earlier version of the label also featured what would have been the biggest single shift in label taxonomy, had it made it to this final version. All percentages were moved to the left, rather than the right. This saved time for someone who already knew how the label worked and just wanted to quickly check the percentage of fat or carbohydrates in a food. "Although it’s atypical to present information like that . . . my view was if you're scanning something, it utilized the space in a more elegant manner than your eye going over the column," Grady says.

"We struggled with it 20 years ago; we’re still struggling with it," says Sharon Natanblut, director of strategic communications, FDA Foods and Veterinary Medicine, of moving numbers to the left. They focus tested it. They listened to comments (including at least one industry criticism from the Juice Products Association). "We weren't able to demonstrate that that was going to result in people being able to use that more effectively."

Why Aren’t More Good Ideas Used?

The FDA is notorious for being in the pocket of food lobbyists—which may or may not explain the black hole that seemed to swallow ideas that Grady proposed by the time of the final design. But the food industry certainly spoke up about the proposed changes.

Nestlé lobbied to skirt clarifying disclosures on packaging that ranges between 1.5 and 2 servings—just the sort of packaging that may be small enough that a consumer frequently eats the entire thing. Fiji water complained that, given new label guidelines, the company would need to disclose the sodium in their water that they could formerly round down to zero.

Many rallied against the disclosure of added sugars, including those you’d suspect, like the International Council of Beverages Associations (which includes Coca-Cola, Pepsi, and Red Bull), General Mills, Ocean Spray, the Sugar Association, and the Snack Food Association, along with those you might not, like the National Yogurt Association (confirming what we all knew—that yogurt really does suck without all that fruit on the bottom). Even Gerber argues that added sugars shouldn't be given a percentage Daily Value, and should instead only be listed in grams (it's worth remembering that Gerber is in fact owned by Nestlé). Meanwhile, Kind was one of the few companies saying the FDA didn’t go far enough—urging them to list sugar in teaspoons rather than grams for clarity, and disclose artificial sweeteners more aggressively. (This lobbying is a sort of self-interest in its own way, of course. Kind founder Daniel Lubetzky complained to me recently that the natural sugars in almonds make it looks like his Kind Bars have more added sugar than they do.)

Within all these industry comments, it’s harder to find real responses to the actual design, rather than the content of it. But dig a bit and you find them. The Juice Products Association argued against all of FDA’s biggest design changes to the label—calories being made large and bold, daily value percentages leading each nutrient on the lefthand side, and multi-column views that broke down data like nutrients per container. And they presented two eye-tracking studies (one is on European labels, it appears; the other we cannot find) to support their case—and the 20-year-old label. Meanwhile, General Mills countered that bold and large type created an "overall visual [that] appears dense, complex, and cluttered," arguing that such visual ambiguity can be confusing. But then they lose a bit of credibility when they share this super sad render that implies they could just never get that new label to fit on a tub of Yoplait!

Inching Toward Progress

The final label will be rolled out over the next two years. Despite the back-and-forth in a review process that wasn’t always transparent to Grady, he doesn’t blame the government for the difficulty in making these changes. Instead, he implies that the food industry provided a lot of pushback. "Frankly, there are people whose interests are money as opposed to health," Grady says. "That’s not controversial to say. It’s obviously just true."

Grady doesn't want his updates to the label to become the norm. In fact, he’d prefer not to be remembered for this unfathomably massive project, that will be seen by every U.S. citizen at some point, as his crown achievement, because in his eyes, this work should not be the final solution for a country that’s facing an epidemic of obesity, born largely from the food industry.

"It’s interesting to read the comments. A lot of people have really good points. ‘Why not this? Why not that?’" says Grady. "The way I see it is, it’s all part of an evolution. I wouldn’t expect this to stay the same for the next 20 years like the last one."

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