FDA’s proposed food label not as effective as warning-style designs

Clearer warning-style labels may help shoppers make healthier choices faster, but certain designs can still create false impressions of health and mislead shoppers into thinking unhealthy foods are better than they are.

Study: Efficacy of front-of-package nutrient labels designed for mandatory implementation in the USA: an online randomised controlled trial. Image credit: Deman/Shutterstock.com

Consumer identification of healthy versus unhealthy foods may drive their food choices. A recent study in The Lancet compares a front-of-package label (FOPL) scheme proposed by the Food and Drug Administration (FDA) for mandatory implementation with other alternatives to assess their effects on consumer understanding and behavior.

Packaged foods drive excess sugar, salt, and fat intake

Among all food sources, packaged foods contribute the largest share of nutrients of concern: added sugar, sodium, and saturated fat, to the typical American diet. Dietary guidelines recommend restricting intake, as they can increase the risk of noncommunicable diseases.

FOPLs are not mandatory in the USA, but the FDA is now beginning the process to make them so. It is also examining various label designs and, in 2025, published its proposed rule with a description of the label.

This is termed the Nutrition Info Box scheme, listing multiple nutrients of concern alongside the appropriate term, high, medium, or low, with the percent Daily Value (%DV). However, existing literature suggests that qualitative labels may outperform purely numerical formats that interpret nutrition numbers for consumers. For instance, as low, medium, or high for a nutrient of concern, compared to those that provide numerical or quantitative data.

Such labels are already in use in many Latin American countries and have been associated with improvements in consumer behaviour and product reformulation. This is supported by other experimental and observational evidence, according to the authors. Policy evaluations also suggest that labels indicating high nutrient content of concern effectively improve consumer behavior and motivate better formulations of packaged foods.

In view of these apparent contradictions between the FDA-proposed label and other commonly used label types, the current study aims to directly assess their impact on consumer understanding, perceptions, and behaviour, comparing them with each other and with a no-label condition.

Testing various FOPLs against no-label

The researchers conducted a randomized controlled trial on 13,929 American adults, who were randomized to view products labeled according to one of five schemes:

• No-label (control)
• Nutrition-Info-%DV – the FDA-proposed label
• Nutrition-Info-Red –nutrients of concern at high levels in red, no %DV
• High-In – all nutrients of concern at high levels listed on one label
• Multi-High-In – all nutrients of concern at high levels listed on separate labels

The aim was to assess consumers’ ability to correctly identify the most and least healthy products by nutrient profiles; how they perceived the healthfulness of unhealthy products (low in two but high in one nutrient of concern); and the label’s impact on the selection of foods.

Multi-High-In labels perform strongly

All FOPLs enhanced consumers’ understanding of the nutrient content of various packaged foods, although differences between labels were generally modest in terms of understanding outcomes. They also reduced the selection of foods high in nutrients of concern.

Among the tested outcomes, Multi-High-In and Nutrition-Info-Red achieved better results than Nutrition-Info-%DV on multiple tasks. Ease of understanding and use: both Nutrition-Info-Red and Multi-High-In outperformed Nutrition-Info-%DV. Consumer understanding improved most among less educated and less nutritionally aware consumers, but less among those with children.

Nutrition-Info-Red and Multi-High-In were most effective at identifying the healthiest and least healthy foods, compared to Nutrition-Info-%DV, though all FOPLs improved consumer performance.

Compared to no labels, FOPLs were associated with misperceptions (sometimes described as a “health-halo effect”) about the healthfulness of foods with a severely mixed nutrient profile. These are foods high in one or more nutrients of concern but low in others, comprising 40 % of packaged foods. The study used foods such as beef jerky, candy, soft drinks, and sweetened yogurt in this category.

Nutrition-Info-Red led to greater health-halo effects (ie, increased perceived healthfulness of some unhealthy foods) than Nutrition-Info-%DV. According to the authors, this may be because it uses the terms Low, Medium, and High, where Low can convey a false impression of healthfulness. Thus, the Low label in foods with a severely mixed nutrient profile may produce a false “health-halo” despite the labeling of nutrients of concern at high levels in red.

Nutrition-Info-Red discouraged unhealthy food shopping choices more than Nutrition-Info-%DV. Nonetheless, all FOPL labels were associated with a lower likelihood of selecting an unhealthy snack than controls, for themselves or their youngest children.

High-In and Multi-High-In were more likely to be noticed, and Multi-High-In was more likely to be used, compared to Nutrition-Info-%DV. Multi-High-In, followed by Nutrition-Info-Red, accelerated consumer evaluations of the least healthy and healthiest nutrient profiles by 21-30 % compared to Nutrition-Info-%DV.

Even without explicit briefings, all FOPLs decreased selection odds for foods high in nutrients of concern.

Simple “high in” labels show strongest real-world potential

The results suggest that the most useful packaged food labels are those that flag a high content of nutrients of concern, generally achieving better outcomes than the FDA-proposed label. For instance, Multi-High-In had several distinct advantages.

It enabled rapid customer evaluations of food products, with Nutrition-Info-%DV being the slowest. It had the highest consumer recall; was used the most; and reduced consumer selections of foods high in nutrients of concern the most. Compared to Nutrition-Info-Red, Multi-High-In reduced the perceived healthfulness of foods high in nutrients of concern in almost all cases.

Nutrition-Info-Red was associated with the most accurate understanding of nutrient profiles, perhaps because it replaces numerical information with content highlighted in red. However, it also produced the strongest health-halo effects, highlighting a trade-off between improved understanding and potentially misleading perceptions.

The FDA described High-In labeling as performing differently in prior evaluations, though the current study found high recall, correct assessment of foods high in nutrients of concern, improved food selections, and better response time than Nutrition-Info-%DV.

Importantly, the authors list confounding factors that might have driven these discrepancies. These include the FDA’s use of isolated FOPLs rather than labels on food packaging and its use of different nutrient profiles for different labels. The Nutrition-Info label also used icons and colors not in the High-In labels, and participants were not told the implications of High-In, which always indicates a food with high levels of one or more nutrients of concern.

Strengths and limitations

Despite the strengths of this study: a large sample, a randomized controlled design, and FDA-similar methodologies to increase comparability, it has some limitations. For instance, hypothetical food selections were assessed. Summary labels were not used for comparison (instead of providing information on individual nutrients, these contain the overall score of the food).

In addition, consumers were asked to select foods based on specific nutrients of concern, and only modest differences in consumer understanding were observed between labels. This may reflect an artificial setting in which labels received more attention than is typical in the real world.

Label designs specifically highlighting products’ high content of nutrients of concern, like Multi-High-In, outperformed the FDA’s proposed label and should be prioritised for consideration in FOPL policies.

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