Does the FDA really think 12 ounces is the same as 20?

The FDA recently released a proposal that would update packaged food labels to “reflect the latest scientific information.” They are taking public comments here and here until June 2nd, 2014. Some of the more salient changes include

New FDA Food Label What is Different

  • disclosing “added sugars” in addition to natural sugars;
  • adding a column to include both “per serving” and “per package” calorie and nutrition information;
  • and highlighting “calories”, “serving size” and “percent of daily value” through changes to the size, style, and position of font.  

Many of the new rules improve clarity and relevance of the labels, which will provide consumers with more accurate information. But will we make better choices?  Access to open and accurate information does not necessarily lead to healthier behavior, in fact, it could result in exactly the opposite.

In particular, there is one component of the new rules that could result in poorer eating behavior: the FDA is increasing serving size for larger containers in order to “better align with how much people really eat.” 

There is a large body of literature that shows the size of food containers influences the amount of consumption. In other words, the larger your bowl of popcorn, the more popcorn you will eat (and doesn’t matter if the popcorn is really bad). Part of the new FDA rules will reflect this research by increasing serving size to take changes in the amount of food consumed as a result of different package sizes into account. In effect, larger packaging will have larger serving sizes such that a 12 oz bottle of soda and a 20 oz bottle of soda are both a single serving. This update is an attempt to align with legislation that requires serving size to reflect the amount people actually eat. The current serving sizes are based on surveys conducted in the 1970’s and 80’s. Since then food packaging sizes have increased dramatically, and consumption along with it. Thus, the FDA is increasing the serving size to reflect changes in how much people are eating today. This is a misuse of the research. Think of it this way, if a recent survey showed people are driving faster today than they were thirty years ago, and there is clear evidence that people are driving faster today because their cars have more horsepower, should the government then increase the speed limit for cars with more horsepower? It doesn’t make any sense. While people eat more as a result of larger food containers it does not mean that they were unsatisfied when they ate less from a smaller container nor that it is safer to eat more. Further, just because we eat more from a larger container does not mean we actually want to eat more if someone asked us. Perhaps the law should reflect what is safe, and how much the average person eats (and wants to eat) after controlling for external factors (often manipulated by industry) that influence when our body tells us we’re satisfied.

FDA Serving Size Infographic

The FDA has proposed a dual label which displays caloric and nutritional information per serving and per container. Saving the public the burden of arithmetic.

The FDA has proposed a dual label which displays caloric and nutritional information per serving and per container, saving the public the burden of arithmetic.

Another justification for changing serving size goes something like this: “When the serving size is less than the package size, consumers have to do mental math to figure out how many calories are in the package.” This is bad because math is evil. Who wants to do arithmetic? But in all seriousness this is a legitimate concern. Math takes up valuable time and mental energy, and frankly most people won’t bother. The problem is, this point is no longer relevant as the FDA is also introducing a “dual column” feature that shows caloric information “per serving” and “per container” so we don’t have to remember to “carry the one” when counting calories. 

Another concern of mine is how industry and consumers will react to these changes in serving size labeling. Industry might wonder, “why offer a 12 oz soda when a 20 oz soda is also one serving and we can charge more?” The consumer might think, “why buy the 12 oz soda when the 20 oz doesn’t cost that much more and is also just one serving?” The new serving size label also allows for easy rationalizations of poor eating habits, “I shouldn’t drink this whole soda, but it’s ok because it’s just one serving.”

There is much yet to be discovered as to how the new presentation of information on food labels will actually affect behavior. But it is important to remember that information by itself doesn’t always lead to behavior change and, if it does, the resulting behaviors could be detrimental to our health. I believe there will be negative consequences that come from labeling serving size by container size. If you agree, tell the FDA to remove this part of the new rules because 12 ounces is NOT the same as 20. Also I encourage you to explore all changes for yourself. I believe many of the new rules are at least a step in the right direction.


3 thoughts on “Does the FDA really think 12 ounces is the same as 20?

  1. Interestingly, the answer to the question in your headline is, “No, but they are required by law to think it.” I’m on board with changing the law. (What’s the name of the relevant statute?)

    “There is much yet to be discovered as to how the new presentation of information on food labels will actually affect behavior.” I would not be shocked if the literature suggested that nutritional labels have very little effect on eating habits. So while I don’t disagree with anything in this post, I’d be pretty shocked if the new labels moved the needle on public nutrition.

  2. FDA’s Proposed Rules on Food Labeling – A blog by Richie LeDonne

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