Key Issues

NMPF is also engaged on other food labeling issues, including how to label bioengineered foods, what should bear the label of “natural” or “healthy”, the U.S. Food and Drug Administration’s proposed front-of-package label.  

Our Positions 

In addition to enforcing the existing standards of identity for dairy products, it is important that FDA has clear, common sense definitions for terms commonly used on food labels. Some of the top labeling issues include:  

Use of “Healthy” on food labels

The thresholds required for the “healthy” claim on food packaging only account for a narrow view of overall human health and will result in many consumers missing out on nutrient-rich foods, including dairy products.

• FDA published its final rule defining the term “healthy” in the Federal Register in December 2024. This final rule defines what food products can use the term “healthy” on their labels and reflects an updated approach to the label claim initially introduced 30 years ago.
• Under the previous version, about 15% of products were eligible for the healthy designation, but FDA’s new definition is so narrow that only 5% are now expected to qualify.
• Certain nutrient-dense foods will earn the “healthy” designation, including low-fat dairy products, beans, lean meat, olive oil and avocados. Given the strict limits on salt, added sugar and saturated fat, reduced fat (2%) milk or sweetened yogurt will not be eligible, even though they contain abundant, foundational nutrients for human health.
• Certain plant-based beverages may be able to qualify if reformulated to the low sugar threshold.

Front-of-Package nutrition label

NMPF opposes FDA’s proposed rule to require that saturated fat, sodium and added sugar be displayed prominently on the front of packaged foods.

• The FDA is proposing to require a front-of-package nutrition label on most packaged foods to provide “at-a-glance information to help consumers quickly and easily identify how foods can be part of a healthy diet.”
• The proposed nutrition label, referred to as the Nutrition Information Box, would be added in addition to existing Nutrition Facts Panel required on most food packages.
• Because the front-of-pack label would only list saturated fat, sodium and added sugar, consumers will get an incomplete picture of that food’s nutritional profile.
• NMPF asserts that the proposed rule, as it is currently written, is unlawful, will not be able to withstand a First Amendment challenge, and should be withdrawn.

Use of “Natural” on food labels

• The FDA has considered the term “natural” to mean that nothing artificial or synthetic (including all color additives regardless of source) has been included in, or has been added to, a food that would not normally be expected to be in that food.
• However, this policy was not intended to address food production methods, such as the use of pesticides, nor did it explicitly address food processing or manufacturing methods, such as thermal technologies, pasteurization, or irradiation.
• The FDA also did not consider whether the term “natural” should describe any nutritional or other health benefit.
• NMPF has advocated that cheese in particular has a long history of being referred to as natural and that should continue, and that many other dairy products also qualify to use the term “natural”.

Defining cell-based products

NMPF staff have also elevated the need for FDA to develop labeling standards for cell-based products to end dairy product mislabeling and prevent a repeat of the plant-based labeling mess.