Are You Ready for the New U.S. FDA Nutrition Facts Table Regulations?
The greatest U.S. regulatory change to affect packaging in the last 20 years was recently completed. The Nutrition Facts Table (NFT), seen on all food and beverage products sold in the US, is changing – and all companies with revenues over $10 million must comply by updating every piece of packaging artwork that contains an NFT before July 2018. This is a complex challenge due to the tremendous volume of work and the need to ensure the label layout is exactly as described by the FDA.
Changes to the new NFT include a refreshed design with a number of nutritional modifications. (See Image 1.) Some of the key differences include:
- Highlighting Calories and Servings.
- Serving sizes that more closely reflect the amounts of food that people currently eat – not what they should eat.
- Added Sugars to specify how much sugar has been added.
- “Dual column” labels to indicate both “per serving” and “per package” calorie and nutrition information.
- Removing Calories from Fat, because research shows the type of fat is more important than the amount.
Beyond updating all packaging artwork, tasks will likely include a full review for accuracy, reprints, and filling and shipping products to retailers – all within tight deadlines. It’s a daunting prospect. In fact, because this is such a major change to the label content, many brands are considering redesigning or updating their entire labels.
The logistical challenge is developing a clear and simple update process, as well as creating an established packaging workflow for future regulatory compliance. Establishing a reliable workflow, simple approval, and quality control capabilities, as well as NFT templates for easy placement into packaging artwork, will enable rapid development of compliant packaging.
Using this change as a driver for an established regulatory workflow doesn’t need to be difficult. Also, once created, new regulations can be managed without too much business disruption. Compliance to most regulations requires six factors:
- Updated content should be centralized and must be 100% accurate.
- The brand owner needs an updated layout of the new or existing information as prescribed by the regulatory body.
- Designers need to determine correct placement of the updated content.
- There must be tight review and approval cycles of the updated artwork.
- Automated quality control of content and artwork would be helpful, to assure all errors are caught.
- The entire process must be transparent and traceable.
This can be accomplished by decoupling the content and layout process, and establishing a firm workflow, so content and materials flow as quickly as possible, accelerating the arrival of compliant packaging on the shelf.
Matching the method to the brand owner
Here are three methods of reworking labels, each defined by where the target information is currently held—typically by the brand owner, within the artwork, or in some other external system. By choosing the method most suited to the current situation while using updated Nutritional Facts templates, each organization can be confident that they will optimize their process—leading to compliance now and easy compliance to future regulations.
Method 1 starts with the brand owner. (See Image 2.) If your data resides in different systems or files, you can centralize the information by entering data into a templated online database. Nutritional information can then route for review and approval before being linked into an NFT in the artwork. Verifying the data before formatting in the artwork will optimize the nutrition labeling process and create a single source of truth, which can be easily leveraged online or in other multi-media beyond packaging artwork.
Method 2 starts with the artwork. (See Image 3.) If the data source is the current artwork and data is not digitally managed, there are ways to export the data directly from Adobe® Illustrator®. Graphic artists can use Illustrator plugins to guide the entry of nutritional information into FDA compliant templates. These templates will ensure the correct content is captured and formatted per the regulation. The data from these dynamically generated tables is then output into a database for collation of the missing elements and approval routing. Once approved, the finalized data is automatically linked back into the Adobe Illustrator plugin to automate table creation and/or updates. Creating dynamic tables and centralizing the data make future updates quick and easy.
Method 3 is full system integration. (See Image 4.) If your nutrition information is available in a structured fashion within other external systems, you can automate the data collection process to create or update the NFTs, so your data comes from external sources rather than being manually entered. Similar to the other methods, it is then routed for review and approval and automatically centralized for future updates.
The new NFT will ultimately provide more clarity for consumers, but transitions like these can be complex and disruptive – and, with the focus on consumer safety and health, these will likely become more frequent. These three tailored methods are suggested to allow choices for the brand owner based on what works best. It is recommended that you adapt the packaging process to embrace, rather than fight, this trend.