US Food Labelling Update
More than 40 countries already have front-of pack, or FOP, label requirements.1 These help consumers make smarter decisions about buying food products high in certain nutrients, like saturated fat, sodium, and sugar.
While there are no federal US requirements for FOP labels now, it’s only a matter of time. The US Senate already proposed amendments to the Federal Food, Drug, and Cosmetic Act including FOP labels. Working off of this, the FDA has spent the past couple of years conducting study groups on possible designs.
When we, at Crew Marketing, spoke to the US FDA's Mark Kantor, he told us: "[FOP Labeling] is not yet a legal federal requirement" but the "FDA is planning to propose a new regulation regarding front-of-package nutrition labeling."
Understanding and preparing for these changes early can help you get ahead of the competition in making formulation changes, redesigning packaging, and redistributing compliant products in stores.
Find out more about where US packaged food labeling requirements are headed from our food marketing experts.
Understanding the FDA Proposal
While nothing’s set in stone yet, the FDA has been testing out FOP design options for more than two years now. Based on their focus group findings, here’s what we can expect.
What Are FOP Labeling Requirements
The purpose of FOP labeling is to limit confusing marketing messages on food and beverage products. It’s aimed at more quickly educating shoppers on the actual nutrition content of a product before purchase. In the US, legislators are hoping these labels will help combat diet-related conditions like obesity, heart disease, and diabetes.
The FDA has been studying other countries’ implementation of the labels and testing similar designs with US audiences. They’ve taken inspiration from places like Canada, Mexico, and the UK.
Canada’s FOP Standards
The newest of the bunch, Canada’s FOP standards officially go into effect in 2026. Their labels use a magnifying glass icon next to black bars indicating that a product is high in sat fat, sodium, or sugars. Similar to Canada, the FDA is considering label designs that show when specific nutrients are “high.”
Mexico’s FOP Standards
In 2020, Mexico enacted black stop-sign-shaped FOP labels like many other South American countries. These labels indicate “excess” levels of calories, sugar, sodium, or sat fat. Going off of this, the FDA is considering adding calories to their list of FOP inclusions.
The UK’s FOP Standards
The FDA’s proposal may take into account the UK’s color weighing of nutrient amounts considered “low,” “medium,” or “high.” In the UK, they use stop light coloring, with low as green, medium as amber, and high as red to make labels easier for consumers to understand.
Key Elements of the FDA Proposal
FDA front label designs, although not yet released, will likely include the following.
- Clear information about serving size, including number of servings per pack if three or more
- Details about key nutrients like calories, saturated fat, sugars, and sodium
- A grading system for nutrient levels, like percentage daily value (DV), the words “high in”, or ratings of low, medium, or high on each nutrient
- Maybe color coding, either like the UK’s stop light method or colors specifically assigned to each nutrient
Impact on CPG Brands
No matter which design the FDA goes with, there’s no way around it — CPG brands will have to make huge packaging changes to fit these new labels. Some brands may also consider reformulation so they don’t have to claim “high in” multiple ingredients.
Compliance and Regulatory Considerations
We’re not sure of the exact timing yet, but the FDA hopes to unveil their design this summer. Once regulations are fully decided, based on other countries’ rollouts, we’d expect a reasonable implementation timeline to be at least two years.
After this period is up, brands who aren’t compliant might face legal and financial consequences. On top of that, stores may refuse to sell non-compliant brands, giving more shelf space to competitors who follow the rules.
Packaging and Design Changes
FOP labels are meant to be eye-catching and disruptive, making them clunky on existing packaging. Brands are probably going to have to change their front packaging designs pretty significantly to incorporate the labels without compromising branding.
This is especially concerning for food brands planning to launch new products within the next year or two. It would be costly and ineffective to release a product and then immediately have to redesign its packaging before it's even recognizable to shoppers.
Keeping these issues in mind, budgeting and planning for packaging redesigns should start now. If you wait until too late, you might encounter issues from overloaded package designers, manufacturers, and distributors. On top of that, you may not have enough time to come up with innovative packaging solutions or potential formulation changes to stay competitive.
Turn FOP Changes Into An Opportunity for Your Brand
Preparing for the upcoming FDA FOP labeling requirements will protect your brand from legal issues, fines, and competitive disadvantages. At Crew Marketing — a trusted global CPG marketing agency — we’ll make sure you’re ready.
We’ve dealt with these types of rules before and know how to best incorporate FOP labels into packaging designs without disrupting your brand. We’re also keeping a close eye on developments, so you can subscribe to our newsletter for FDA regulation updates.
Ultimately, though it might seem like a problem, FOP labels can be an opportunity to grow consumer trust in your brand. We can help you leverage this change — contact our team for personalized consulting on FOP labeling compliance.
US FOP Labeling FAQs
Need quick answers to your burning US FOP labeling questions? Find them here.
When will these changes go into effect?
The FDA has vaguely indicated that their design should be unveiled sometime in 2024 or 2025. After that, we suspect brands will have two or more years to fully implement the new labels.
Where can I find more information?
The US Senate’s “Food Labeling Modernization Act of 2021” is available in full online. Section two addresses FOP labels.2
The US FDA also addresses packaged food labeling requirements including a page on FOP labels.3
References
- Holdship, D. (2024, April 29). It’s time to rethink food labels. Michigan Today. https://michigantoday.umich.edu/2024/04/25/its-time-to-rethink-food-labels/
- S.2594 - 117th Congress (2021-2022): Food Labeling Modernization Act of 2021 | congress.gov | library of Congress. (n.d.). https://www.congress.gov/bill/117th-congress/senate-bill/2594
- Center for Food Safety and Applied Nutrition. (n.d.). Front-of-package nutrition labeling. U.S. Food and Drug Administration. https://www.fda.gov/food/food-labeling-nutrition/front-package-nutrition-labeling
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