"Allowing a “healthy” label only on foods low in sugar, sodium, and saturated fat discriminates against many of the most nutrient-dense foods that contain under consumed nutrients of public health concern. The front-of-package “nutrition information box” for rating saturated fat, sodium, and added sugar as high, medium, and low is also concerning because it causes confusion."
ADC criticizes the FOP label as misleading:
"To call the front-of-label rating box “nutrition information” is a misnomer. The most nutrient dense natural foods that are high in nutrients of public health concern are also above the thresholds being set for saturated fat and sodium. For example, most natural and minimally processed dairy foods, as well as all natural meats and other animal-derived products, would not be permitted to make a healthy claim or use the healthy label under the rule FDA is finalizing. This is a travesty to Making America Healthy Again."
They argue the FOP label lacks real nutritional context:
"The front-of-label ‘nutrition information box’ contains no ‘nutrition information,’ which will confuse consumers and direct them away from reading the back-label containing actual nutrition information!"
ADC also notes that even nonfat dairy products often require added sugar to be palatable, especially for children. They warn that the sodium limits would exclude nearly all dairy products, despite their high nutritional value.
"These FDA rules will further reduce consumption of these foods and nutrients – because of saturated fat and sodium content. This outcome is especially harmful to growing children."
ADC concludes that the proposed rule could harm public health, particularly for children who rely on school meals.
The full text of the ADC's comment is available here.