On June 15, the FDA published a 30-day procedural notice on its plans to conduct a study about front of package (FOP) labeling, entitled “Quantitative Research on Front of Package Labeling on Packaged Foods.” The study is a follow up to focus groups that were conducted in 2022 that tested FOP concepts and draft FOP schemes.

The study will have two main parts: (1) a within-scheme comparison and identification of healthfulness profile and (2) a single-product (and scheme) evaluation. In Part 1, study participants will be given three levels of healthfulness (most, middle, and least healthful) on FOP draft schemes and will be asked to identify the most and least healthful profiles. In Part 2, participants will be randomly assigned to either a food product, scheme type, or level of healthfulness, and will be asked to use the label image to respond to various measures of the label’s effectiveness based on product perceptions (e.g., healthfulness and contribution to a healthy diet) and label perceptions (e.g., believability and trustworthiness).

The FDA is exploring the development of an FOP system to help consumers interpret nutrition information on food products. FOP labeling is intended to complement the Nutrition Facts Panel labeling by giving consumers additional context to identify healthier food selections. In the notice, the FDA states that “[t]he experiences of countries worldwide that have adopted front-of-package labeling suggest that such labeling may help nutrition comprehension and the ability to make healthier choices.”

Stakeholder comments are due by July 17, 2023. Please feel free to contact Keller and Heckman at fooddrug@khlaw.com for assistance providing FDA comments.