Agency Information Collection Activities; Proposed Collection; Comment Request; Quantitative Research on a Voluntary Symbol Depicting the Nutrient Content Claim “Healthy” on Packaged Foods

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment again on the U.S. Food and Drug Administration's (FDA's) planned consumer research to test a voluntary symbol depicting the nutrient content claim "healthy" on packaged foods. From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies who help produce frozen foods and beverages for today's food service and retail marketplace and serve as economic pillars within their communities throughout the U.S. The frozen food industry contributes approximately $65.1 billion to U.S. GDP and accounts for 670,00 U.S. jobs. In addition to our members' strong role in economic growth, AFFI members share a commitment to transparently communicating information about the nutritional content and ingredients in the foods they produce and sell. We appreciate FDA's consideration of the comments we submitted in response to the agency's May 7, 2021, notice regarding the planned research. We appreciate that FDA has agreed to address our comment that the agency should thoroughly evaluate the extent to which a symbol might convey implied messages unrelated to the healthy criteria. We agree that adding an open-ended question to the experimental design asking consumers what the symbol brings to mind will help determine whether any symbols should be removed or revised on this basis. We are disappointed, however, that the agency has decided to proceed with the consumer research before updating the healthy definition. See attached file(s) for more comments.

The American Frozen Food Institute (AFFI) appreciates the opportunity to comment on the U.S. Food and Drug Administration's (FDA's) planned consumer research to test a voluntary symbol depicting the nutrient content claim "healthy" on packaged foods. From manufacturers to distributors to suppliers to packagers, AFFI is proud to represent publicly traded and family-owned companies who help produce frozen foods and beverages for today's food service and retail marketplace and serve as economic pillars within their communities throughout the U.S. The frozen food industry contributes approximately $65.1 billion to U.S. GDP and accounts for 670,000 U.S. jobs. In addition to our members' strong role in economic growth, AFFI members share a commitment to transparently communicating information about the nutritional content and ingredients in the foods they produce and sell. AFFI agrees with the FDA's general approach in considering a "healthy" symbol that is voluntary, positive, and objective. We nevertheless have a significant concern that it is premature to conduct consumer testing on a potential "healthy" symbol until the updated healthy criteria are finalized. We also raise in our comments below the general principles that we believe should be followed in selecting potential symbols for consumer research and in designing the research. Please see attached comments for more details.