Newsletter | Flipping the Script on Food Policy

A couple of recent developments on the nutrition front caught our eye. First, as expected the FDA released its final rule on when food manufacturers can claim that a food item is “healthy.” (We wrote about industry pushback to the “proposed” rule here in – checks notes – April, 2023.) The rule hadn’t been updated in three decades and we now have 300 pages of very precise standards dictating, for example, how much added sugars, sodium and saturated fats can be included in a “vegetable product” and still be called “healthy.” The controversy over the rule seems a bit ironic because, as Nicholas Florko reports in The Atlantic, the rule isn’t likely to have much impact. The FDA, in reporting its rule, included an economic impact assessment that was based on the estimation that 0 to 0.4% of Americans would make meaningful, long-lasting changes to their diets as a result of the rule. Zero to 0.4%. Not a typo. The number is so low that some industry representatives argued that given this expected impact, the rule wouldn’t materially advance the FDA’s interest in reducing chronic illness. Ouch.

Image by Tung Lam from Pixabay

The FDA has, since 2018, required chain restaurants of a certain size to label their menus with calorie counts for each item. A recent systematic review of the evidence of the impact of the menu labeling policies from the renowned Cochrane Collaborative found that the impact – in terms of calorie reduction – is about 1.8%. This change, Sara Todd points out in her report on the study in STAT, amounts to choosing a 589-calorie meal instead of a 600-calorie one. Let’s be fair – it’s not nothing – but it’s also not a lot. Todd’s article also shares the critique of the calorie-centric focus of menu labeling policies as being too simplistic, which ties back to the larger challenge of communicating the complexity of nutrition guidance to a public that struggles to understand it, yet alone apply it.

The limited impact of information-focused interventions on shifting the American diet makes sense in the context of a fascinating piece, by Shayla Love in The Atlantic, on the unconscious nature of habits. In “Invisible Habits Are Driving Your Life,” Love notes:

“Indeed, modern researchers have discerned that habits are practically automatic ‘context-response associations’—they form when people repeat an action cued by some trigger in an environment. After you repeat an action enough times, you’ll do it mindlessly if you encounter the cue and the environment.”

So much of what we do is triggered by the places we’re in, what we see and hear, and what we associate with other actions we take. We learn responses to those triggers and then more often than not, repeat those responses rather unconsciously. We might associate certain fast food restaurants with our lunch hours, or errands we run and so we stop in. We might associate certain dishes with those restaurants and order them whenever we go. We might, as research has shown, break out the snacks when we see food ads on TV. Combine these effects with food that is engineered to be “hyper-palatable” and you can see why trying to influence purchasing decisions with information is a tall order. Florko, in his article, speaks to the challenge of making nutrition information salient:

“If [Robert F. Kennedy Jr.] figures out how to actually get people like me to care enough about healthy eating to resist the indulgent foods that give them pleasure, or if he figures out a way to get cash-strapped families on public assistance to turn down cheap, ready-to-eat foods, he will have made significant inroads into actually making America healthy again. But getting there is going to require a lot more than a catchy slogan and some sound bites.”

Don’t get us wrong – it’s super important to provide clear, understandable and actionable nutritional information on the foods we buy. But in comparison to the forces that push us toward unhealthier diets, it yields but modest influence. We'll leave you with these thoughts from Dariush Mozaffarian, dean of the Tufts Friedman School of Nutrition, who recently wrote a commentary about the process of updating the federal government's Dietary Guidelines for Americans (DGA).

“Most importantly, the DGA and [systematic evidence review (SR)] requirements make clear that guiding Americans toward a healthier diet is an unfair fight from the start. The food industry can do almost anything it wishes to our food, combining diverse ingredients, additives, and processing methods with virtually no oversight or required evidence for long-term safety. In contrast, the DGAs and other federal agencies can only make recommendations to avoid certain foods or limit certain manufacturing methods when there is extensive, robust, and consistent evidence for harm. In this severely imbalanced playing field, industry wins again and again. With far more Americans ill from diet-induced diseases than becoming healthy, it is time to flip this script. Based on the cautionary principle and the ethical obligation to do no harm, food ingredients, additives, and processing methods must only be used when they meet SR-equivalent standards proving their long-term safety. Moreover, the DGAs should be able to recommend avoidance of any foods not meeting such standards of evidence.”

Flipping the script to shift the burden of evidence to the food purveyors is a bold proposal to be sure, but when it comes to the food environment and diet-related diseases, we desperately need bold thinking -- and bold action.

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