What’s Up With Healthy Foods?

Gary C. Smith, Colorado State University 

Being able to call a food or beverage “healthy” has never been about benevolence. To a dehydrated person, water is healthy. Water is considered “essential to human health” by the Department of Water Resources in the State of California.¹ To a person who is malnourished or starving, anything they can eat that has any amount of calories and/or nutrients is healthy. During World War II, starving persons in Nazi-surrounded Leningrad ripped down their wallpaper, boiled it, and survived on wallpaper paste.  

“Healthy” Introduced as a Marketing Strategy 

To some food marketers, it’s all about “market share”; they use “healthy” as a cudgel to make you believe that the offerings of their competitors are “unhealthy.” It’s a dog whistle. It’s like a candidate with nothing to offer except demonization of their opponent. 

The Regulations about making health claims on food labels date back to the Nutrition Labeling and Education Act of 1990. Prior to that Act, putting a health claim on a food label was prohibited.² Then, Kellogg™️ wanted to make claims about diet and health on their cereal boxes, so Congress decided to open it up by giving Regulatory authority to FDA.² What most people ate for breakfast was low-hanging fruit for the “cancellation basket”; they weren’t ever going to be able to qualify as “healthy”. Those at the lever of FDA still worshiped at the throne of Ancel Keys and had blessed the Dietary Guidelines For Americans; in no way would FDA ever allow butter, eggs, ham, sausage, or bacon to be categorized as “healthy.” Those foods had already been found guilty of containing sodium, cholesterol, and/or saturated fat.³ End game? Market share.   

Most of What We Know About Fats is Wrong 

Nina Teicholz got it right when she concluded that all of our dietary recommendations about fat – the ingredient about which our so-called health authorities have obsessed during the past 60 years – is not just off track, it’s completely wrong.³ Almost nothing that we commonly believe today about fats generally and saturated fats in particular appears, upon close examination, to be accurate.³  

How did we get to this place? She blames… 

• Food companies that corrupted nutrition recommendations toward their profit-driven ends 
• Nutrition scientists at some of our most trusted institutions, hastening to address growing epidemics of chronic disease, over interpreting weak and impressionistic data shaped by passions verging on zealotry – they allowed weak science to become dietary dogma³ 

Food Marketers Promote “Clean Eating” 

In the last 10 years, food marketers have run amok trying to come up with food descriptors (e.g., “Green”, “Real”, “Clean”, “Clear”, etc.) they can use as label claims on new products or to bolster existing, but waning in popularity, brands.⁴  

Some say that such labeling is deceptive and puts fear into consumers; some say it’s gotten ridiculous out there and is time for food companies to stop trying to hype their products with meaningless distinctions.⁵ Only “Clean” has gained any traction; and, to many, “Clean Eating” necessarily implies that any other form of eating is dirty, impure, and bad.⁶  

“Healthy” Eating Claims Miss the Mark 

During the period of 2015 and 2020, food marketers began to tout “consumer-lifestyle” movements; 6 of 8 such movements used “Clean” or “Cleaner” in their moniker and 8 of 8 used “Health”, “Healthy”, or “Healthful” to describe their intent.⁷  

Food marketers envision a pot of gold at the end of the “healthy” rainbow, but so far: (a) “Clean” won’t do it; when asked, “What does the term ‘Clean Label’ mean to you?”, no respondents to a survey mentioned nutrition or health.⁸ (b) Critics don’t support it; in a world where 21,000 die each day from lack of nutrition, we should not support use of a cheap marketing gimmick like “Clean Food” as a way to claim health/nutrition benefits to capture the dollars of an elite upper crust of the affluent citizens.⁹ (c) The matter of what is considered “healthy” food and what can be legally labeled as “healthy” has not yet been reconciled.¹⁰  

On Sept. 28, 2022, FDA officials issued a proposed rule to update the definition of the “healthy” claim on food packaging; interested parties have about three months to comment on it. In 2020, USDA published a “Healthy Label Rule” for review and public comments in the Federal Register.¹² But, so far, nothing more has happened on the USDA proposal. 

FDA Wants Consumers to Make Informed Decisions 

FDA believes that making a health claim on a food label allows consumers to make informed choices. As of 2022, FDA has authorized 12 “food/ingredient-health connection” claims “because they are truly backed by the totality of scientific evidence.”² These include the following:  

• Osteoporosis: calcium, vitamin D 
• Cancer: dietary lipids, vegetables, fiber-containing grain products, fruits 
• Coronary Heart Disease: dietary saturated fat, cholesterol, fruits, vegetables, fiber-containing grain products, soluble fiber, soy protein, stanols, sterols 
• Dental Caries: dietary non-cariogenic carbohydrate sweeteners 
• Neural Tube Defects: folic acid 
• Hypertension: sodium²  

FDA Approves “Qualified Health Claims” for Some Foods 

In addition, FDA has approved about 30 “Qualified Health Claims” for some foods or ingredients with some – but not complete – evidence, in which case the claim must be accompanied by a disclaimer sentence.² Generally, FDA believes that a product allowed to make a “healthy” claim must be low fat, low in saturated fat, and low in cholesterol plus also be a good source of one or more vitamins or minerals.¹³  

However, in 2016, FDA issued a Guidance Document stating, “Products that are not low in Total Fat but have a fat profile that is predominately mono-unsaturated and poly-unsaturated fats or are a good source of potassium or vitamin D can use the term “healthy” in labeling and advertising.¹³ In early 2022, FDA announced that it “will not object to” the use of qualified health claims regarding the consumption of magnesium and a reduced risk of hypertension.¹⁴ USDA has announced that meat, poultry, and egg products will be able to use the word “healthy” on labeling and in advertising if their fat content consists mostly of monounsaturated or polyunsaturated fats, as opposed to saturated fats.¹⁵ 

Definition of “Healthy” Comes Under Scrutiny 

In 2015, FDA announced it was contemplating revision of the definition of “healthy” (an implied nutrient content claim), saying it seeks to better align the claim with “current understanding” and “the Dietary Guidelines For Americans (DGFA),” and asked for public comments.¹⁶  

The problem with that is two-fold:  

• There is no consensus on what “healthy” means 
• The DGFA has shifted its guidance from “nutrients” to “food groups”¹⁶  

FDA received 1,139 public comments; FoodMinds® (a food and nutrition consulting company) used a subset of those and concluded that the majority of comments favored eliminating the “healthy” claim altogether.¹⁶ Since then (largely by use of the media), others have favored banning the use of the term for one or more of the following foods:  

• Red meat 
• Processed meat 
• Fruit juice 
• Candy 
• Sugar-sweetened foods and beverages 
• Cheese 
• Grain 
• Refined grain 
• Soybeans 
• Milk and dairy products 
• Corn 
• Wheat 
• Poultry 
• Sugar 
• Processed food 
• Hydrogenated vegetable oils 
• Plant-based meat alternatives 
• Eggs^16-24   

Relative to nutrients per se, FDA says a “healthy” claim is allowed if a food is low fat, low in saturated fat, low in cholesterol, and a good source of one or more vitamins or minerals.¹³ But others believe in limits on or minimization of one or more of trans fats, sodium, processing, refinements, sugars, sweeteners, calories, carbohydrates, and ingredients.^22,25-30  

Yet others believe that “all proteins are not created equal”; so, protein quality (digestibility plus amounts, profiles, and balance of essential amino acids) must be characterized.^31-34 Opinions on fat as a criterion for segregating “healthy” from “unhealthy” foods are split, with some preferring elimination of “fat content” altogether (because the science on this subject is unsettled), to some who believe that food products with higher ratios of monounsaturated and/or polyunsaturated fats as opposed to saturated fats would automatically qualify for a “healthy” claim.¹⁶  

Consumers Look to Nutrition Facts Over Ingredients to Gauge Healthfulness of Food 

Consumers believe that the “Nutrition Facts” panel on a food label is more important in determining “healthfulness” than the “Ingredient List.”³⁵ When reading the Nutrition Facts panel, “sugar” ranks at the top of what adult consumers look for (56%), “calories” are second (45%), and “sodium content” is third (38%).³⁶  

When it comes to which foods some want to be called “unhealthy”… 

• The veganism-activists at the United Nations want meat, poultry, eggs, and milk to be designated “unhealthy”¹⁹  
• American Society for Nutrition wants processed foods plus all other foods that contain too much sodium and/or saturated fat to be called “unhealthy”²²  
• EAT-Lancet says the two “unhealthy” foods are red meat and sugar³⁷  
• Dietary Guidelines For Americans doesn’t identify foods as “unhealthy”, but DGFA, Center for Science in the Public Interest, Nutrition Policy Panel, the “deep state” at FDA and USDA, and Physicians Committee for Responsible Medicine are decidedly against animal-based foods^38,39 

How do we Quantify “Healthfulness” of Food? 

Several entities have developed systems to quantify the relative “healthfulness” of foods. Nutri Score® ratings, developed by Attest™️, claim to be based on a scientific assessment of a product’s combined nutrient quantity, quality, and balance.⁴⁰ It appears that the ratings will be used for advertising purposes and/or as validation for use of a logo on the package.  

American Heart Association uses nutritional and scientific guidelines to determine if the product is “Heart Healthy®”; if so, the product can bear a logo.²³ The American Society of Nutrition uses a Healthy Eating Index®, which assigns points for eating fruits, vegetables, whole grains, and protein and for avoiding processed foods, refined grains, sugar, and saturated fat.²²  

The EAT-Lancet Commission has ranked >8,000 foods and assigned Food Compass Scores® (from 0 to 100) based on the following:  

• Nutrient Ratios (unsaturated:saturated fat; fiber:carbohydrate; potassium:sodium) 
• Vitamins 
• Minerals 
• Food Ingredients 
• Additives 
• Processing 
• Specific Lipids 
• Fiber and Protein 
• Phytochemicals⁴¹  

Foods with scores of 70 to 100 are “highly encouraged, no limitations”, 31 to 69 are “consume in moderation,” and 0 to 30 are “limited consumption.”⁴¹ 

Do We Really Need “Healthy” as a Descriptor?  

Perhaps not. According to the Deloitte Food Value Equation® survey, shoppers are purchasing food based upon: First (No. 1) taste, then price, convenience, safety, (No. 5) health and wellness, sustainability, and last (No. 7) social impact.⁴²  

If we do need to set standards, we shouldn’t depend on complying with the standards for Dietary Guidelines For Americans for the following reasons:  

• The majority of the evidence cited by the DGFA Advisory Committee does not support its conclusions^{3,29,43,44,45}  
• FDA does not believe protein needs to be on the Nutrition Facts panel or in DGFA “because Americans already eat enough protein”³⁰  
• Some saturated fats are actually good, not bad, for peoples’ health^{3,37,38,43,46}  
• Available research does not support the DGFA position on low-carbohydrate diets^29,32,47,48  
• DGFA does not admit that plant-based foods have major deficiencies in calcium, essential fatty acids, essential amino acids, heme iron, vitamin B₁₂, taurine, carnosine, beta-lactoglobulin, lactoferrin, CLA, and immunoglobulins^{30,32,34,49–52}  
• DGFA makes a case for “lower is better” policy on sodium intake, while available data reveals that a “moderate amount of sodium” is better for the majority of people²⁹  

What About Those Food Compass Stores®?  

The food industry will push for the use of FCS as the definition of healthfulness.⁵³ The system creates a problem because FCS rates fruits and vegetables as almost the only foods that score 70 to 100 (“consumption to be encouraged”), no meat/poultry/egg/dairy foods have scores of 70 or higher, and beef, pork, cured meat, and cheese all had scores of 29 or lower (“foods to be minimized”).¹⁸  

It is appalling that the system ranks Lucky Charms®, Cheerios®, and Cocoa Puffs® above all meat, poultry, and dairy products because the scientists who developed FCS assume that all saturated fat is bad, and it counts nutrients added (for fortification/supplementation) as the same as those present in natural foods^.41,53   

Animal-Based Food Provides Much of Our Nutrients 

For those who want to relegate animal-based food to the trash heap, consider the following:  

• Alternative proteins alone can’t feed the world; if we try to, we’ll see increased soil erosion and use of pesticides and fertilizer. When you take the most nutrient dense foods (meat, eggs, milk, and poultry) off the planet and try to replace it with peas and beans, we’re going to have to eat a lot more of it.⁵⁴  
• While only 30% of US food calories come from animal-based foods, that’s how our citizens get 70% of their protein; they provide all our vitamin D and calcium; and most of our vitamin B₁₂, vitamin B₆, zinc, and selenium. How many animal products can we take out of our diet and still stay “healthy”?²⁰
• Scientists from four countries examined the health effects of meat consumption in 175 countries using detailed data collected by the United Nations. Their conclusion was: “Meat intake is positively associated with life expectancy. The underlying reasons may be that meat not only provides energy but also provides a complete set of nutrients for the human body. Meat has been an indispensable component in the human diet for millions of years. The complete nutritional profile of meat, and human adaptation to meat eating, have enabled humans to gain many physical health benefits, including greater life expectancy”^55,56    

Details of FDA’s proposed rule to update the “healthy” claim have been posted in the Federal Register and comments can be submitted to www.regulations.gov. Highlights of the proposed rule are: (a) It generally relies on DGFA and current Recommended Daily Allowances of certain nutrients; (b) it uses a food group-based approach in addition to nutrients to limit saturated fat, sodium, and added sugars.  

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