The FDA’s New Proposed Definition of ‘Healthy’ Is a Positive, but Pretending the Term Can Ever Be Clearly Defined Isn’t
In a statement, the U.S. Department of Health and Human Services secretary Xavier Becerra celebrated the new proposed rule, stating that the "FDA's move will help educate more Americans to improve health outcomes, tackle health disparities, and save lives." But despite the good that can come from updating an outdated definition of "healthy," it's about time we address the real issues and potential harm that can also stem from labeling foods with the word. For that reason, we sat down with the experts to outline how the FDA's determination to provide the term "healthy" with a clear-cut definition may cause more harm than good.
The history behind the FDA's definition of "healthy"
In 1994, the FDA issued a regulation that defined "healthy" as "an implied nutrient content claim pursuant to the Nutrition Labeling and Education Act (NLEA) of 1990." Similar to today, the FDA considered a food "healthy" if it could help consumers "maintain a healthy dietary practice." The initial definition of "healthy", however, primarily focused on a food's total fat, saturated fat, cholesterol, and sodium content. The FDA also required manufacturers to provide a minimum of 10 percent of the Daily Value (DV) of one or more of vitamin A, vitamin C, calcium, iron, protein, and fiber in order to call their food "healthy."
The definition remained generally untouched until the food company KIND filed a citizen petition to the FDA requesting the agency rethink its labeling standards and its definition of "healthy." KIND's request came after the FDA sent the company a warning letter for referring to their snack bars as "healthy" despite having higher amounts of saturated fat (a result of the bars' base of nuts and seeds). Although the FDA later allowed KIND to refer to their products as "healthy," this petition shined a light on the agency's need to revisit how "healthy" was being defined, especially considering how much nutrition science has evolved since the early 1990s.
Fast forward to present: The FDA plans to update the definition of "healthy" with a food group-based approach that focuses on overall dietary patterns. Their new guidelines will hone in on saturated fat content versus unsaturated fat content, and will require food products to limit sodium and added sugars. (Previously, nutrient-dense foods like salmon, avocado, and nuts didn't fit the bill due to overall fat content.) In the proposed amendment, the FDA states that their new definition is intended to help consumers maintain healthy dietary practices "by helping them achieve a total diet that conforms to dietary recommendations."
The drawbacks to having a clear-cut definition of "healthy"
While there can be some benefits to consumers knowing which products meet the FDA's new requirements, experts aren't fully on board for having a clear-cut definition of the word "healthy"—and for valid reasons. "I think [the new proposed rule] comes with a lot more questions than answers and contributes to the already increasing obsession with eating 'clean' and subsequently disordered eating," shares Elaina Efird, RDN, CEDRD, CSSD, the lead dietitian at the Kahm Clinic in Burlington, Virginia who specializes in the treatment of eating disorders. "There are so many factors when it comes to food, so labeling one food as 'healthy' and another as not creates a stigma that is unnecessary. This will likely cause more harm than good."
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For one, using the word "healthy" as a marketing term—a term which can have very different meanings for each individual—can impact a person's relationship with a given food. "The new proposed rule will, without a doubt, trigger individuals with eating disorders and disordered eating because their eating disorder will take it as, 'well if that food isn't considered healthy, then why eat it?' This can increase their restrictive habits," says Efird. "Things that always seem to be left out are [with definitions like this are]: Is the person simply eating enough? When we get into the weeds of what's defined as 'healthy' and 'unhealthy,' people tend to obsess over these foods and restrict intake, which is much more detrimental to the body and mind. Eating disorders have the second highest mortality rate of all mental illnesses, second only to opioid overdose. We have to start considering the eating disorder population instead of sweeping it under the rug."
Virginia Sole-Smith, the author of the Burnt Toast newsletter and The Eating Instinct: Food Culture, Body Image and Guilt in America shares similar sentiments. "The determination to define the word 'healthy' ignores the very real epidemic of eating disorders—where fixations on 'healthy' food become decidedly unhealthy and ignores the even larger epidemic of food insecurity," says Sole-Smith.
Giving the word "healthy" a clear-cut definition also impacts minority communities, many of which already cope with their culturally-relevant foods being villainized by westernized, white-washed nutrition standards. "The U.S Dietary Guidelines have a tendency to vilify cultural foods because in some cases they don't contain 'enough' veggies or are based in white rice. We need to consider the fact that some dishes just aren't high in vegetables. And that's okay! Everyone should feel safe and secure cooking the foods that they grew up with as opposed to what the FDA deems 'healthy,'" says Efird.
Indeed, while it is important to "eat the rainbow," this concept of solely focusing on bright and colorful food in order to eat "healthy" excludes white and brown foods that are integral to many cultures' cuisines. Different cultures simply prioritize produce, flavors, and ingredients in different ways. While the new rule may exclude many cultural foods that are nutritionally valuable, there's also the flip side: Even if a food product is considered "healthy," it still may not fit within a person's flavor palette.
Remember: There are many important reasons we eat, and nutritional value is just one of them. And while having a uniform definition of "healthy" doesn't take into account the complexity behind each person's unique culture, you could say the same about its lack of accountability for an individual's environment, food access, socioeconomic status, personal preferences, and so on. "The 'healthiest' food choice is going to look so different for every person [based on] their culture, overall lifestyle, and finances that exist, but think of the day to day factors, too. If I have a busy day and don't have time to make homemade meals, then getting fast food for dinner is still going to be significantly 'healthier' than skipping meals," says Sole-Smith.
The assumption that keeping a "healthy" label on foods will address the rise in chronic diseases and help Americans live healthier lives dismisses the a number of other factors—particularly the many social determinants of health—that play a major role in someone's overall wellness. Even if shelves are stacked with food products that meet the FDA's new requirements and proudly market the "healthy" symbol, this still doesn't address why roughly 54.4 million Americans don't have access to nutritious food or live close to grocery stores. "In my experience working as a dietitian for almost a decade, I find that everyone generally knows what is considered 'healthy' by dietary guidelines—the real issues that cause people to struggle with meeting the expectations set out by the dietary guidelines are budget, access to food, and busy lives," says Efird. "In many areas in America, there are food [apartheids] with limited access to grocery stores, or lack of transportation to get to these grocery stores. I think addressing the affordability of 'healthy' foods, American work expectations, and the food apartheids present across America are far more important than establishing a clear-cut definition of the word 'healthy' on packaging."
Splashing more food marketing labels—or updated versions of them—on food packaging says Sole-Smith, is not the answer. "Most consumers don't need more nutrition education; they need money to afford the food they want to buy, and they need to be able to trust themselves and their bodies around food," she says. "Taking such a narrow approach to health that's only measured in terms of weight and nutrition is not serving anyone. These messages shame and stigmatize fat folks [and] anyone who can't measure up to the government's nutritional standards, which is disproportionately low-income folks and folks of color."
The bottom line
It's safe to say that the FDA's update to the definition of "healthy" was much-needed in order to account for modern nutrition science. Still, giving the term a definition in the first place is capitalism at its best, and it fails to address the very individualistic, very personal nature of what it means to eat "healthy."
In the meantime, Efird advises remembering that this new proposed rule or "healthy" food label does not mean you only have to eat those foods. "You can choose some of those foods but also other foods that fit with your budget and your dietary preferences. And if you can't afford the foods labeled as 'healthy,' there is no shame in that," she says. "You are not doing anything wrong by purchasing the foods that fit your budget to feed you and your family, [plus] it's okay to just enjoy food!"
What's important is making decisions you're happy with and feel good about, regardless of whether or not it includes a certain label on food packaging. "Prioritize meals that are relaxing and enjoyable over rigid nutrition rules, and give yourself full permission to eat the foods you crave. When meals are a source of joy, not stress, then nutrition tends to work itself out," says Sole-Smith.
Whether you choose to buy food labeled as “healthy” or not, what’s important is knowing what the word “healthy” means to you—and listening to that.
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