How do you define “Healthy”?

Labeling certain foods as “healthy” implies that eating those foods are positive for your health and eating ones without a label, are not. Theoretically, this sounds amazing – shopping for healthy foods goes on autopilot and diet-related diseases suddenly disappear. If only things were so simple. The reality is that a healthy, nutritious diet can’t be deduced down to choosing-- or avoiding-- certain foods or nutrients that meet certain criteria. Speaking of, what magical combination of nutrients defines a “healthy” product anyhow? And who gets to decide this, the Government?

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The Food and Drug Administration (FDA) first defined “healthy” in 1994 and placed heavy emphasis on lower fat content. Thirty years later and this definition hasn’t stood the test of time. This is partly due to the knowledge gained from the tens of thousands of studies over the past three decades. But I like to think “healthy’s” lack of durability is largely due to a concept well-understood by dietitians and grandmas – a single food doesn’t make or break a healthy diet and a healthy diet isn’t defined by a few criteria.

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Inevitable holes in FDA’s definition of “Healthy” came to a head in 2015 when KIND (the snack-bar maker) was warned by FDA that some of its products could not call themselves “healthy” due to their higher-than-allowed total fat content. While KIND complied by removing references to “healthy”, they raised an important question—aren’t some fats, like those from the nuts in KIND bars, considered healthy fats? This pushed FDA to reconsider the term.

In 2016, FDA began its nearly eight-year process to redefine “healthy”, seeking public input in several fora, including on its most recently proposed definition in September 2022. We remain in limbo while we wait for FDA’s final rule (expected last month, April 2024). The term “healthy” (and variations or synonyms used on labels) has been the source of contention, class-action lawsuits, and delayed rulemaking. Why? Because it is very difficult, limiting, and controversial to classify certain foods as “healthy” and others (by implication) as not.

As we wait with bated breath for the final “healthy” rule, I still have a lot of questions: What combination of nutrients will the Government determine constitutes a “healthy” product this time around? Will the new definition of “healthy” stand the test of time? How many new “healthy” products will hit the market in the next few years? Will consumers seek out these “healthy” products? What happens when someone eats “healthy” foods in excess? Will consumers feel misled that “healthy” products may have less sugar, but include artificial sweeteners instead? What if “healthy” foods have more calories? Will choosing “healthy” products lend itself to positive health outcomes?

Defining and labeling foods as “healthy” is not necessarily the magically simple solution to a complicated issue – and it may even backfire. Yet, it seems that the FDA thinks we can fix the nation’s obesity and diet-related disease problems through regulating labeling of the food supply, thus incentivizing reformulation. Reformulation using what? That should always be your first question. Is it more calories? Is it ingredients you don’t want, or your body can’t tolerate? Diet is personal, it’s complicated and everyone needs more nutrition education.

My hope is that it is evidence-based facts that are considered in future FDA labeling directives and not subjective value judgements. For now, we just sit and wait for a healthy definition and a proposal on front-of-package labeling. More on the latter later.