FDA Mandated Changes Coming In 2018
August 1, 2016
There are several articles and blogs that predict a lot of doom and gloom regarding the upcoming FDA deadline. Yes, there's a lot of new analysis that needs to be done, and a lot of files to update. Every SKU will need to be touched. With a deadline of July 26, 2018 (or 2019 if you have fewer than $10 million in revenue), there's time to optimize the cost of reprinting to include new graphics, communication or even different sizes or structures. Why not use this to your advantage and consider an update to your brand? The results could have a very positive impact.
Several reasons behind the FDA mandate are consumer driven. Are you still reaching your target audience, have their needs shifted or has your audience migrated since your last restage? The market is constantly evolving. How can you take advantage of this opportunity to tell a better story that connects with consumers, including your brand loyalists?
Let's look at some of the reasons the FDA is mandating these changes to see how they could be optimized for your brand versus simply changing a nutrition facts table.
• Improved scientific information linking diet and health
Consumers care more and more about what they're eating. There's a shift away from processed foods to simple ingredients, and a desire for transparency to actually know what they're eating. The simple act of updating the nutrition facts tables will drive more people to look at the nutrition facts – whether they typically do or not. New information about added sugars, trans fats, and changes in the nutrients listed, will result in product comparisons by consumers. Should you consider an update to the product formulation? Knowing consumers won't compromise taste, and will continue to indulge, should you consider a different brand position?
• Serving size doesn't accurately reflect what is customarily consumed
This can be a challenge for consumers, which is why there is a market for 100-calorie packs. Portion control can be difficult, particularly if you're engaged in multiple activities at once. It's easy to eat more than one serving from a bag of snacks while concentrating on writing a blog, for example. It happens with the best of intentions. Armed with this information, how can you help your consumer make healthier choices or easier decisions, even without reformulation? Consider new communication on pack, or new sizes. Making their lives easier can be rewarding in multiple ways.
• Changed priorities for dietary guidance
The current FDA label format is more than 20 years old. Our population has changed and the new requirements are based on dietary deficiencies and excesses that have changed over time. The American Heart Association, the American Academy of Pediatrics, the Institute of Medicine, the World Health Organization and the Centers for Disease Control and Prevention, among others, have all contributed to these changes. Guidance regarding added sugars, trans fats, fiber, Vitamin D and Potassium, as well as calories, are changing based on needs of the current general population. How can you use this opportunity to help educate your customers about the new label, and endorse the changes that support a healthier population?
Even though the ruling is final, not all of the details have been finalized. There's still a lot we don't know, such as how facts on front nutrition keys may change, or if there will be USDA changes. We're waiting on details about dietary fiber; and if all products on shelf have to be completed, or if a soft rollout is acceptable.
There is a lot that we do know. All CPG companies have the same opportunity to update and potentially expand their consumer base. Simply changing the nutrition facts table, may not provide the best ROI. The more time you allow to strategically implement a change to your brand and how it connects with your consumers, the more impactful that change can be. And finally, we are ready to help.