Implementation of a Revised Food Labeling Policy: Evaluation and Tracking

ABSTRACT - The paper reviews the environment in which FDA is revising the food labeling regulations regarding nutrition information and ingredients. The problem of raising the salience of nutrition to the public is discussed from education and marketing perspectives. FDA plans are outlined for introductory consumer education on how to use the new label, including the need for evaluative research and market tracking of the rate of new label adoption by the food industry.


Raymond E. Schucker (1981) ,"Implementation of a Revised Food Labeling Policy: Evaluation and Tracking", in NA - Advances in Consumer Research Volume 08, eds. Kent B. Monroe, Ann Abor, MI : Association for Consumer Research, Pages: 493-496.

Advances in Consumer Research Volume 8, 1981      Pages 493-496


Raymond E. Schucker, Food and Drug Administration


The paper reviews the environment in which FDA is revising the food labeling regulations regarding nutrition information and ingredients. The problem of raising the salience of nutrition to the public is discussed from education and marketing perspectives. FDA plans are outlined for introductory consumer education on how to use the new label, including the need for evaluative research and market tracking of the rate of new label adoption by the food industry.


The program of research and development in support of a revised food labeling policy will require approximately four years to bring to the point of national implementation. The first two years, 1978 and 1979, were concerned with identifying what changes should be made in food labeling information based on consumer expressions of interest from survey research, public hearings, representations of consumer need by organized consumer groups and consideration of public health as seen by food and nutrition professionals. Tentative positions on a number of food labeling issues were published in the Federal Register of December 210 1979.

In the next twos years three parallel efforts yell tom-place the development phase of the revision of the food label. A series of experimental laboratory studies will be conducted to screen and identify the more promising label formats from among a large array of alternatives which will be created by a professional design firm. These studies are discussed in greater detail in another paper of this session. In a continuation of the tentative initiatives announced in the 1979 position paper FDA will publish, invite public comment, revise and issue specific regulation providing for certain expanded nutrition and ingredient information for which the Agency already has authority under the Food, Drug and Cosmetic Act. These include labeling the source of fat, requiring quantitative declaration of the amount of sugar, sodium and potassium, and establishing definitions for low and reduced sodium and cholesterol. A regulation defining levels for low and reduced calories became effective July 1980. For certain other desired food label changes FDA does not currently have legislative authority and will need to seek authority from Congress during this period, notably to require nutrition labeling on more foods and to extend specificity of ingredients declarations along a number of dimensions. The third effort during the remainder of the policy formulation and development stage will involve assessment of the economic impact of the proposed label changes on the food industry and the assessment of possible increased food costs against anticipated consumer benefits. Economic analysis of proposed regulatory actions is required where potential impact on the regulated industry is anticipated to exceed $100 million.


For a number of reasons, including lack of defined regulatory authority on the part of FDA, economic impact of the label revisions, or failure of the consumer laboratory research to sufficiently narrow the range of label format alternatives, it is not possible at this time to forecast in complete or final detail what the policy revision will be or to mark a clear point in time when the process will move out of the policy formulation-development stage into an implementation phase. However, for purposes of planning and discussion, it is convenient to establish the implementation phase as beginning in mid 1983 which is the uniform effective date set by FDA for industry compliance with final label change regulations growing out of the December, 1979 tentative positions.

Based on an FDA survey in the Fall of 1978 (Heimbach and Stoker 1979). overt consumer internee in improved food label information about nutrition or ingredients ranged between 8 - 15% among food shoppers, conservatively estimated through nondirective questioning. This is interpreted by some industry opponents of further change in food labeling as reflecting a low level of interest in label information and is raised as an objection to further regulation at this time. Whether one accepts FDA's more conservative estimate or other higher estimates of demand for information, such as have been published from time to time based on claimed use of or preference for food label information, consumer interest is not expected to increase in the near future and may even be eroding somewhat as other more pressing food concerns arise. In the general inflationary spiral of the late 1970's. accompanied by rising food prices, consumers began to become increasingly leery of Government regulatory action that might contribute to further increases in the cost of food. Most published consumer surveys continue to identify price as an overriding critical factor in food purchasing.

Of greater significance than the absolute level of consumer demand for nutrition and food ingredient information is that the nature of concern about food has generally turned away from emphasis on setting enough of the essential nutrients to avoidance of the consequences of overeating, particularly obesity. Also, uncertainty about the function, necessity and even safety of food preservatives and additives in general has led to an avoidance set among increasing members of consumers in their selection of food. Organized attempts are growing to press for the removal of questionable ingredients from the food supply where particularly vulnerable segments of the population are thought to be at risk. An example is the national network of parents groups that support the Feingold hypothesis linking certain color and flavor additives to hyperkinesis in young children.

The attention of the organized consumer movement in the last two years has also shifted somewhat away from the longer term issues of health and nutrition. With the exception of concern about the health effects of anger consumerists are placing more emphasis on food safety,. government control over environmental contaminants and removal of hazardous substances from foods. Nutrition labeling is not given quite the same priority as during the early and middle years of the decade, and there are no indications on the horizon that the situation will be reversed soon.

Although interest in revising the nutrition label has plateaued and counter pressures have appeared in some public sectors, interest in nutrition information has not declined among food retailers and in fact has been on the rise since publication in 1977 of suggested national dietary guidelines by the Senate Select Committee on Health and Human Needs under the chairmanship of Senator McGovern. Retailer activity accelerated in the latter 1970's as food chains began to develop and implement in-store information programs featuring nutrition. Retailer receptivity to promotional ideas and materials has been great enough that at least one firm is now marketing an in-store nutrition information package to supermarket operators. Other chains have developed and implemented program of their own.

Some of the retailer programs have been found to use nutrition information that is inaccurate or that makes unwarranted health claims and have been in conflict with existing FDA nutrition labeling regulations. Case law growing out of regulations issued under the Food, Drug and Cosmetic Act has led to the interpretation that food information presented in proximity to food products constitutes labeling. Thus, much if not all product-specific nutrition information that is presented in the supermarket is subject to the regulations. In the interests of minimizing consumer confusion while encouraging innovation, FDA has published a regulation permitting retailers as well as manufacturers to request temporary exemption from nutrition labeling requirements for purposes of testing alternative nutrition labeling formats at point of purchase. To date a number of retailers have sought exemptions for experimental programs, and the outlook is for food chains to continue to use in-store nutrition programs as competitive promotional and merchandising tools as long as retailers are convinced this is a service consumers want and will use.

Very little hard evidence is currently available on whether consumers actually modify their purchase behavior as a result of nutrition information disclosure at point of purchase. A recent collaborative effort (report in preparation) between Giant Food Inc. Washington, DC and the National Heart, Lung and Blood Institute tested a year long series of in-store pamphlets containing information on foods useful in an overall program of heart health maintenance. Supporting radio and newspaper advertising was also used. Sales in a matched panel of test and control scores were audited, and pre and post consumer interview surveys were conducted to track awareness and knowledge of the campaign, as well as specific elements of health information that had been presented. Some campaign effects were detected in the interview data, but no sales changes were observed that could be attributed to the nutrition information program.

Giant Food Inc. has also requested an exemption to conduct an additional two-year nutrition information program involving special shelf edge labeling for food brands that are reduced, low in, or free of sodium, cholesterol, fat and calories. Advertising will support the program in one market, while both shelf labeling and advertising will be withheld from a control market. Sales in a matched panel of stores will be tracked via electronic scanning of the universal product codes of nutrition labeled foods versus their unlabeled regular counterparts. Results of this and other experimental studies in supermarkets are not likely to be available in time to impact implementation of the label revisions in 1983.


Although an effective date of mid 1983 has been set for industry compliance with the new or revised food labeling regulations, the individual regulations will actually issue at different points in time prior to the effective date. Some food manufacturers will begin to phase in revised labels as soon as necessary analytic information has been obtained to support newly required label declarations and when convenient with respect to label production and inventory cycles. Consumers will therefore experience a trickling in rather than an abrupt introduction of the new food label format.

Informing Versus Educating

The nutrition professional community and educators for a number of years have stressed the need for an overhaul of the basic four food groups approach to nutrition and for greater government support to develop curricular and teach nutrition at the primary and secondary levels. Viewed against the background of dissatisfaction with the level of nutrition knowledge and dietary practices of the U.S. population, FDA's program to revise the food label is seen in perspective as an effort to improve the information base which consumers need in order to make better nutritional food purchases. However, by no means does food labeling constitute education in the sense of teaching skills or modifying behavior. FDA has no legislative mandate or funding to develop curricula or otherwise to engage in basic long term education. The Agency currently envisions developing a short term, perhaps two-year program of introductory announcements and instruction on how to understand and use the revised food label. The program will be delivered through the print and broadcast media. In addition, instructional presentations such as slide shows will be distributed at the community level by FDA's field network of Consumer Affairs Officers.

Little guideline information is available on the resources and national level of effort that might be required to raise public awareness and change attitudes toward a subject so technically complex and burdened with difficult scientific vocabulary as nutrition. Even less is known about whether lasting behavioral changes can be achieved, let alone sustained, without massive support over a long period of time. The traditional education approach is generally criticized as having been less effective in raising the nutritional well being of the population than the direct interventions of food fortification or the various government supported feeding programs such as the school lunch programs.

An education framework may not be the most useful approach to determining what needs to be done to raise the nation's nutrition consciousness. The marketing approach, to take a different view, would focus on identifying then solving consumer nutrition-related needs and problems. This perspective on nutrition brings at least two issues into relief.

The first is that nutrition problems are generally perceived as not very immediate. Cardiovascular disease and hypertension may not produce a stroke or coronary for decades. Sugar in food is less popularly recognized as a promoter of calories than as a contributor to weight gain. Even overweight and obesity, although highly visible precursors of possible future health problems, may not be threatening today. In short, consumers don't have problems.

The second issue stems from the first and is the need to raise the salience of nutrition, i.e., to motivate consumers to want to behave as though tomorrow's health problems are really today's concerns. These two aspects of nutrition must be addressed in any national policy which seeks to achieve broadbased improvement in food and dietary behavior through consumer voluntary action. The magnitude of the requirement suggests that an educational approach alone will not be adequate to the task, nor does the superficial marketing analysis of the problem provide any ready suggestions as to how to solve it, or indicate the level of national effort and time frame that will be required to effect meaningful change.


In part because of the complexities of nutrition discussed previously, as well as time and resource constraints the experimental laboratory research to select an improved label format will be restricted mainly to criteria that demonstrate the consumer's ability to comprehend food Label information and make appropriate product decisions regarding nutritional quality or ingredients composition. Consumer satisfaction with quality of decision making will also be used as a criterion measure in evaluating alternatives. On the other hand, the research conducted in the label development stage will not deal with consumer motivation to use information, or with intentions or other behavioral type criteria.

Unresolved Issues

Given the numerous elements of graphic design that might be used in formatting nutrition and ingredients information, it is possible, even likely, the research will show that a number of alternative label information displays are equally effective in meeting the criteria of comprehensibility and utility in product decision making. Ultimately it may be appropriate to permit use of alternative formats to accommodate different package sizes and shapes. One school of thought proposes marketplace testing after the experimental laboratory type research in order to select a final label or two on the basis of demonstrated effects on food sales. However, to use a marketplace test for a run off of labels, in addition to being costly, would confound the issue of consumer ability to understand and apply information with the issue of willingness to use it. Moreover, in the typical 'noisy' market test employing a sales criterion manure, the odds do not favor the detection of consumer behavior change in response to revised nutrition label information alone in the absence of other efforts to begin to deal with the motivational side of the problem.

Use of multiple communication channels to deliver nutrition information has been proposed as a partial solution to the problem of raising the salience of nutrition, for example, by making a generic or even brand specific food information handbook available in the home for use in menu planning. Another suggestion has been to place similar information in a reference book in grocery stores, including nutrition information for fresh fruits, vegetables and meats, which are now exempt from nutrition regulations.

The current surge of retailer interest in featuring nutrition at point of purchase opens up possibilities for controlled store research using actual sales data to test variables that could enhance the impact of the revised food label as national implementation begins. An example might include use of the shelf edge to highlight selected new elements of nutrition information not previously appearing on food labels. Short term special floor displays in high traffic areas of the store might group an array of products having one or more of the same nutrition characteristics. Also, the food retailer's weekly newspaper feature ad might offer the opportunity to deliver nutrition information in conjunction with promotional pricing, which has high salience for the consumer.

Experimentation is also needed to establish the content of nutrition messages and weight of effort required in the broadcast media, use of which may believe is necessary if all sectors of the public are to be effectively reached and influenced by nutrition information. The grocery store in today's favorable retail climate is an appropriate focal point for designing and executing sensitive studies of behavior response to multi source communications, such as retailer and public service advertising, as well as locally produced radio and television shows covering nutrition related health subjects in community service time slots.

Program Evaluation

FDA's regulation permitting exemption from strict adherence to nutrition labeling for experimentation purposes includes the requirement of a formal evaluation component. On request the Division of Consumer Studies, Bureau of Foods, has been cooperating with food retailers in reviewing and offering comment on the design of such studies, which are expected to continue as in-store program are developed to tie in with implementation of the revised labeling regulations. Evaluation studies have included the use of survey based consumer measures and score based sales criteria in pre versus post design employing treatment groups only and also in more complex experimental designs using both treatment and control groups.

Through the mechanism of its annual food shopper survey the Agency will measure growth in consumer awareness and response to the introduction of the new label in relation to a benchmark point prior to the effective compliance date at retail. Evaluation criteria will include knowledge of newly added nutrition information, comprehension of nutrition vocabulary items targeted for revision, knowledge of new classifications for foods on key nutrients, such as calories, sodium and cholesterol, and consumer satisfaction with the quality of nutrition decisions made in food purchases.

The annual shopper survey will also be used in the evaluation of the two-year introductory education campaign now under development. Of particular concern is that the campaign, as well as the revised label, reach the poor, the undereducated and those who are not information seekers. The education campaign will include script and materials tailored to half-hour television and radio program to be produced locally and featuring some aspect of the newly revised nutrition label as it relates to health, such as sodium and hypertension. These will be evaluated in terns of extent of acceptance by television stations for production, actual airing in local came slots, and size and composition of audience reached. Local consumer surveys will be conducted to determine relative impact of local versus national programming.

Market Tracking

For the near future, manufacturers will continue to have considerable latitude in deciding voluntarily whether to offer nutrition information at all on the food label. Until FDA obtains greater regulatory authority nutrition labeling will be required only if nutrients are added or advertising or nutrition label claims are made. Thus the rate at which the revised regulations impact the consumer will be tied in part to the extent of industry adoption and rate of changeover to the new format.

FDA will establish a benchmark level of nutrition labeling in the U.S. food supply under the current format via a food labeling and product surveillance survey which is conducted biannually based on a probability sample of packaged food products purchased from the retail shelf (Schucker 1978). Content analysis of the labels in terms of projected national sales of the sampled brands will permit tracking of the rate of changeover to the new food libel by product class. The survey will also be used to assess quality of adherence to the specific labeling requirements of the regulations and to provide feedback to the regulatory compliance arm of the Bureau of Foods. Finally, label content will be tracked over time for indications of manufacturer use of nutrition and ingredient information for marketing, advertising or promotional purposes beyond simply meeting the requirements to list the information in the label section reserved for this purpose.


Consumer demand for nutrition information on the food label has plateaued recently, partly because of concern that government regulation will contribute further to inflation and rising food prices. Another factor has been the shift in concern from nutrition related food issues to health and safety questions about food additives and preservatives. Finally, concern about nutrition is turning away from nutrient deficiency to nutrient excess and health consequences of overconsumption.

In contrast, food retailers have shown growing interest in nutrition and are purchasing or developing their own in-store information programs. FDA has encouraged retailer experimentation with alternative ways to present nutrition information and by regulation requires an evaluation component to be included in such special programs. For these reasons the supermarket is an appropriate focus for experimentation during the implementation of the revised food label beginning in mid 1983. A basic need is for research to determine how to raise the salience of nutrition is the general public, to develop meaningful nutrition communications content, and to estimate the level of national effort that will be required, particularly in broadcast media.

FDA will use its annual food shopper survey to evaluate at the national level a consumer education campaign introducing the revised food label. Local consumer surveys and audience statistics will serve as a basis for evaluating television script packages designed for production by local television stations. The rate of food industry changeover to the new food label will be tracked via an ongoing biannual study based on probability sampling of packaged food products at retail.


Heimbach, James T. and Stokes, Raymond C. (1979), 'FDA 1978 Consumer Food Labeling Survey", Division of Consumer Studios, Bureau of Foods, Food and Drug Administration, Washington, DC.

Schucker, Raymond E. (1978), "A Surveillance of Nutrition Labeling in the Retail Packaged Food Supply", Division of Consumer Studies, Bureau of Foods, Fond and Drug Administration, Washington, DC.



Raymond E. Schucker, Food and Drug Administration


NA - Advances in Consumer Research Volume 08 | 1981

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