In January, the U.S. Food and Drug Administration proposed requiring a front-of-package nutrition label for most packaged foods. The proposed “Nutrition Info box” provides information on saturated fat, sodium and added sugars content in a simple format showing whether the food has “Low,” “Med” or “High” levels of these substances.

FDA is inviting comments on the proposal through May 16, 2025. Not surprisingly, several parties have already weighed in on the proposal.

I think The Tea Association of the U.S.A., Inc., made some valid points in its submitted comments regarding the product it represents.

The group’s position is that “the FOP label is not necessary or helpful to aid consumers in choosing tea for its many beneficial properties. Tea contains virtually no sodium, saturated fat, or added sugar, and because of this, tea leaves and tea powders are exempt from the requirement to use nutrition facts labeling. Tea is often packed in small boxes allowing for limited space to bear the FOP label.”

The group adds: “The cost for tea manufacturers to comply with FOP labels would be prohibitive and would make the cost of tea higher, potentially limiting its accessibility to consumers who can benefit greatly from its many proven, powerful health benefits.”

The National Milk Producers Federation (NMPF) also submitted a detailed argument against the proposed FOP labeling.

“FDA’s proposed Front-of-Pack rule not only fails to improve consumer understanding but instead encourages consumers to make dietary decisions based on a new misleading box that provides an incomplete assessment of a food’s nutritional profile,” NMPF says. “The rule aims to reduce consumption of certain nutrients without regard to beneficial nutrient content that may help consumers meet much-needed dietary targets for key things such as protein, vitamins, minerals, and more.”

As in the case of The Tea Association of the U.S.A., the milk producers group raises concerns about cost.

“As the FDA is aware, label changes are expensive. Food manufacturers have hundreds if not thousands of stock-keeping units (SKUs), each with its own label and frequently they have multiple years of label inventory on hand,” NMPF says. “Not only will the physical labels need to be replaced but the plates that print those labels will need to be replaced. The costs to make the changes are substantial and most food manufacturers operate on tight profit margins which means the additional costs will be borne by consumers.”

Mega PG Distributions LLC, which imports confectionery and snack products into the United States, said in its submitted comments: “Front facing nutritional information is currently being required in Mexico and aside from the initial reaction to this information, consumers have now for the most part begun to ignore this information, and they have returned to their usual consumption habits … As a person involved in the candy & snack industry, I believe that it would be an unnecessary expense to small business in the industry to require modifications to current packaging.”

While the comments that I have included in this column generally share the same perspective, I’m not here to weigh in personally on the FOP labeling issue. I was just genuinely curious as to who had already responded to the FDA proposal, and I wanted to see what kinds of arguments they laid out.

With the comment period running through May 16, Packaging Strategies will continue to monitor the submitted comments and will share a variety of perspectives with our audience.

Brad Addington
Chief Editor, Packaging Strategies
(248) 227-4727
addingtonb@bnpmedia.com