Front of Package Labels: Product Reformulation Considerations

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Front of Package Labels: Product Reformulation Considerations Christine Johnson, MBA Director of Nutrition Policy Cardiovascular Disease Prevention and Control Program NYC Department of Health and Mental Hygiene

NYC Health Department Front-of-Pack Recommendations No industry-created front-of-pack labeling Require a uniform and mandatory labeling scheme Label includes calorie and portion size information Label used as warning for items high in nutrients with negative health outcomes Create national monitoring system to assess changes in nutrient content of products Source: DOHMH submission to the FDA regarding: Front-of-pack and shelf tag nutrition symbols, submitted July 27, 2010.

Findings NYC Menu Labeling NYC Trans Fat Restriction NYC-led National Salt Reduction Initiative

Impact of NYC Menu Labeling Regulation

Consumer Response Calorie Labeling Study Design Receipt collection Data collection Baseline: Spring 2007¹ Follow-up: Spring 2009² Random sample of all stores for the top 13 fast food and coffee chains in NYC 275 locations ¹ Bassett M, et al. Purchasing behavior and calorie information at fast-food chains in New York City, 2007. Am J Pub Health. 2008;98(8):1457-1459. ² New York City Department of Health and Mental Hygiene, unpublished data

Difference in Mean Calories Purchased: Spring 2009 1000.0 900.0 800.0 863 757 * 2009 - Didn't See/Use Calorie Info 2009 - Used Calorie Info 700.0 Calories 600.0 500.0 Customers who used calorie * information purchased 106 fewer calories (p<0.05) compared to those that didn't see or use the information. 400.0 300.0 200.0 100.0 0.0 Lunch Source: New York City Department of Health and Mental Hygiene, unpublished data

Industry Response: Introducing New Products KFC s grilled chicken is promoted as a healthier, lower-calorie option. Original Recipe Grilled Chicken Calories 110-370 70-180 Fat 7-21g 4-9g Source: KFC website, accessed April 2010, http://www.kfc.com/about/newsroom/041409.asp Photo Source: http://www.yumsugar.com/3131387

Promoting Meals Below Specific Calorie Levels Source: http://www.bk.com/cms/en/us/cms_out/digital_assets/files/menu_nutrition/positivesteps.pdf

Preliminary Signs of Item Reformulations Calorie content before and after New York City calorie posting requirement* Calories Brand and Item Name Mar-07 Jun-08 Change %Change Dunkin' Donuts Glazed cake stick 490 360-130 -26.5 Plain cake stick 420 310-110 -26.2 Glazed chocolate stick 470 370-100 -21.3 Plain croissant 330 270-60 -18.2 McDonald's French fries (large) 570 500-70 -12.3 Grilled chicken ranch BLT sandwich 520 470-50 -9.6 Starbucks Blueberry muffin 400 320-80 -20.0 Crispy square 450 440-10 -2.2 Taco Bell Southwest steak border bowl 690 600-90 -13.0 Wendy's Source: New York City Department of Health and Mental Hygiene, unpublished data Chicken club 650 540-110 -16.9 Jr cheeseburger deluxe 360 300-60 -16.7 Jr hamburger 280 230-50 -17.9 *Information from online company nutritional guides accessed March 2007 and June 2008. Some restaurants also launched higher calorie products during this time.

Summary Consumer Response NYC Study: Lunchtime customers who use calorie information consume about 100 calories fewer than customers who do not use the information Industry Response There are many examples of companies reformulating popular products to lower calorie content

Impact of Trans Fat Restriction in NYC Food Service Establishments

NYC Trans Fat Regulation NYC Health Code amendment requires all products in restaurants and foodservice be <0.5 grams trans fat per serving. French fry reformulation to reduce trans fat resulted in an overall decrease in saturated fat + trans fat. Source: Angell, SY et al. Cholesterol control beyond the clinic: New York City s trans fat restriction. Annals of Internal Medicine. July 21, 2009;151:129-134.

Reformulation of French Fries Pre and Post Trans Fat Restriction PRE POST CHANGE Saturated Fat (g) Trans Fat (g) SF + TF (g) Saturated Fat (g) Trans Fat (g) SF + TF (g) Saturated Fat (g) Trans Fat (g) SF + TF (g) Wendy's Kids' Meal 1.5 0.0 1.5 1.5 0.0 1.5 0.0 0.0 0.0 Medium (small) 2.5 1.0 3.5 2.5 0.0 2.5 0.0-1.0-1.0 Biggie (medium) 3.0 1.0 4.0 3.0 0.0 3.0 0.0-1.0-1.0 Great Biggie (large) 4.0 1.0 5.0 4.0 0.0 4.0 0.0-1.0-1.0 McDonald's Small French Fries 2.5 3.5 6.0 1.5 0.0 1.5-1.0-3.5-4.5 Medium French Fries 4.0 5.0 9.0 2.5 0.0 2.5-1.5-5.0-6.5 Large French Fries 6.0 8.0 14.0 3.5 0.0 3.5-2.5-8.0-10.5 Arby's Curly Fries - Small 4.0 3.0 7.0 4.0 0.0 4.0 0.0-3.0-3.0 Curly Fries - Medium 4.0 4.0 8.0 4.0 0.0 4.0 0.0-4.0-4.0 Curly Fries - Large 7.0 5.0 12.0 7.0 1.0 8.0 0.0-4.0-4.0 White Castle French fries, Regular, 4.12oz NY 3.0 5.0 8.0 3.0 0.0 3.0 0.0-5.0-5.0 French fries, Sack, 8.6oz, NY 6.0 11.0 17.0 6.0 0.0 6.0 0.0-11.0-11.0 AVERAGE 4.0 4.0 7.9 3.5 0.1 3.6-0.4-3.9-4.3 Percent Change Average Grams -10.5% -97.9% -54.2% *Information from online company nutritional guides accessed December 2006-February 2007 and April-August 2008. Source: Angell, SY et al. Cholesterol control beyond the clinic: New York City s trans fat restriction. Annals of Internal Medicine. July 21, 2009;151:129-134.

Implications of the National Salt Reduction Initiative and Nutrition Databases

National Salt Reduction Initiative (NSRI) Decrease sodium content in foods by 25% over 5 years Decrease population sodium intake by ~ 20% over 5 years Source: Institute of Medicine. Strategies to reduce sodium intake in the United States, Appendix G. Available at: http://www.iom.edu/reports/2010/strategies-to-reduce-sodium-intake-in-the-united-states.aspx.

NSRI Packaged Food Categories (1) Bakery Products Breads and rolls Sweet breads and rolls Tortillas and wraps Cakes, snack cakes, muffins, and toaster pastries Cookies Crackers French toast, pancakes, and waffles Cereal and Other Grain Products Instant hot cereal Breakfast cereals, light and medium weight Breakfast cereals, heavy weight Meats Cold cuts Pepperoni and dry salami Cooked sausage Uncooked sausage Hot dogs Bacon Uncooked whole muscle meat and poultry Canned meat and sausage Canned chicken and turkey Frozen and refrigerated meat substitutes Dairy Products and Substitutes Grated hard cheese Cheddar, Colby, jack, mozzarella, Muenster, provolone, and Swiss cheese Cream cheese Cottage cheese Processed cheese Fats and Oils Margarine and other spreads Salted butter Mayonnaise and mayonnaise-type dressing Salad dressing Sauces, Dips, Gravies and Condiments Major main entrée sauce Minor main entrée sauce Salsa, dips, and dipping sauce Barbecue sauce, ketchup, marinades, and steak sauce Asian-style condiments Snacks Flavored chips Unflavored chips Puffed corn snacks Popcorn Pretzels and snack mixes

NSRI Packaged Food Categories (2) Soups Canned soup Broth and stock Dry soup Potatoes Frozen and refrigerated potatoes Seasoned processed potatoes Mixed Dishes Frozen entrees and sides < 6 oz per serving Frozen entrees and sides 6-10 oz per serving Frozen entrees and sides 10 oz per serving Frozen and refrigerated pizza Refrigerated entrees and sides Canned chili, pasta, and hash Seasoned pasta and stuffing mixes Seasoned grain mixes Vegetables Frozen vegetables in sauce Canned vegetables Canned whole tomatoes Diced, crushed, and stewed tomatoes Vegetable juice Legumes Baked beans Canned beans Canned Fish Canned fish Seasoning Mixes Dry seasoning mixes Nut Butters Nut butters

NSRI Packaged Food Database Created database, including: National sales data Nutrition data, by UPC For each food category: Analyzed top 80% of items by sales Calculated sales-weighted mean and range of sodium

Model of NSRI Impact 40 35 2014 400 mg 2012 480 mg Mean 531 mg mg/100g 30 25 Frequency 20 15 10 5 0 0-100 101-200 201-300 301-400 401-500 501-600 601-700 701-800 801-900 901-1000 1001-1100 1101-1200 Sodium (mg/100g)

Sample Category Sodium Distribution 70 60 Current Sales- New Weighted Sales-Weighted Mean 531 mg Mean 494 mg Top 30% of volume 646 mg mg/100g 50 Frequency 40 30 20 10 0 0-100 101-200 201-300 301-400 401-500 501-600 601-700 701-800 801-900 901-1000 1001-1100 1101-1200 Sodium (mg/100g)

Finland Salt Reduction Program 1993 - Introduced salt labeling legislation High salt content warning label required for products that exceed set sodium levels Sodium reduction from product reformulation in 5 categories 10% reduction in sausages 20% reduction in bread Source: Karppanen, H and Mervaala, E. Sodium Intake and Hypertension. Progress in Cardiovascular Diseases. Sept/Oct, 2006; 49(2): 59-75.

Monitoring Progress in the Food Supply: A National Nutrition Database NYC DOHMH calls for creation of a public national database: FDA should require industry reporting and make public a database of all Nutrition Facts panel information under the public education mandate of NLEA Require Nutrition Facts labels on packaged food sold to foodservice/restaurants; require to industry to report in database Updated annually Interface for easy public access Able to be merged by UPC Source: Angell SY. Emerging opportunities for monitoring the nutritional content of processed foods. Am J Clin Nutr. 2010 Feb; 91(2):298-299.

Key Considerations Recommend using front of pack labeling as a warning label to drive reformulation. National nutrition database is key to track nutrient changes in the food supply.

Thank You Christine Johnson, MBA Director of Nutrition Policy Cardiovascular Disease Prevention and Control Program NYC Department of Health and Mental Hygiene