We took a review of it, and here are the immediate highlights and concerns.Implementation Period
We are currently in the 90 day comment period. During this time, any person can issue a comment against the regulation via the links above. After the comment period, the FDA reviews the rules, and the issues a final rule. Once the final rule is complete, all food vendors then have two years to make the changes. So as a best guess, food vendors probably have 2.5 - 3.5 to generate this new label.Serving Size Changes
One of the biggest changes is to 'reference amounts customarily consumed' (RACC). In the current food label, the serving size is typically considered the amount of one portion. The FDA is updating the guidance of how a serving size should be defined.
For example, let us say you have one package with two cookies. And on your nutrition facts label, you say one serving size is 'one cookie'. So if you ate both cookies, you are actually eating 2 serving sizes.
In the updated RACCs, there is new guidance to have a single serving container representing one serving. So if you have 1.5 - 2 servings per container, the FDA basically wants you to round up that to one serving size. The draft proposal link above has more detailed information in the different scenarios.Added Sugars
There is a new line item on the nutrition facts label which declares an 'added sugar'. So if you a cake for example, all of the 'granulated white sugar' would be considered an added sugar. If this regulation occurs on the final label, we advise food vendors to think about ways of lowering their added sugars when consumers see these new numbers in the marketplace.
New Micronutrient Declarations
In the current label, Vitamin A, Vitamin C, Calcium, and Iron are mandatory micronutrients. Now they are Vitamin D, Calcium, Iron, and Potassium. In light of this, we advise food vendors to check their formulations against the new micronutrients list.
The new label