Tell FDA your thoughts on the proposed Nutrition Fact Label (by Aug. 1)

A change to the Nutrition Label we are so familiar with and food serving sizes used in labels is currently being considered by the Food and Drug Administration (FDA).

Commenting on the dockets Proposed Nutrition Label represents a key opportunity for diabetes advocacy!


Here are the changes being proposed:Proposed_Label_-_Whats_the_Difference

These proposed changes are addressed in the Food Labeling: Revision of the Nutrition and Supplement Facts Labels docket. You can share your comments about it here. Below (within the “How To Act”) are some recommendations on comments you can share with FDA about this docket.


These proposed changes are addressed in the Food Labeling: Serving Sizes of Products that Can Reasonably be Consumed at One Eating Occasion; Updating of Reference Amounts Customarily Consumed; Approaches for Recommending Smaller Portion Sizes docket. You can share your comments about it here. Below (within the “How To Act”) are some recommendations on comments you can share with FDA about this docket.

For more background, read the FDA’s Guidance Documents & Regulatory Information for Labeling & Nutrition.

In the spirit of following the leaders shared during the recent MasterLab event, it makes sense to share the perspective of the American Diabetes Association (ADA) about the proposed label and food serving sizes. Here is a summary that ADA shared with its advocates recently:

We submitted comments on two proposed rules from the FDA modifying the Nutrition Facts label that appears on most packaged foods in the United States and gives consumers information on the nutritional content of the food. The FDA is proposing changes to the content and layout of the Nutrition Facts label.

In our comments to the FDA, we focused primarily on the pieces of information most important to people with diabetes. As such, we supported the FDA’s plans to require “Added Sugar” content be listed on the Nutrition Facts label.

We also supported the FDA’s plans to increase the font size of the number of servings in the package and the amount of calories per serving.

In addition, we supported the FDA’s use of updated data to determine the serving size for many food categories, and to require packages with between two and four servings to include nutrition information for one serving and for the whole package.

The Association opposed the FDA’s proposal to abbreviate the listing for “Total Carbohydrate” to “Total Carbs” since this could cause some confusion for individuals with diabetes who use the “carb choice” method of tracking their carbohydrate intake.

You can read ADA’s comments to FDA about the Nutrition Label Proposed Rule here, and about the Serving Size Rule here.

Also, Krista Maier, Associate Director of Public Policy at ADA recently participated in an interview on this topic in TuDiabetes. The video explains very well the changes proposed by FDA and ADA’s comments about them. Watch the video here.

How to Act

ADA and others have sent in their comments, but the FDA needs to hear our individual voices as advocates.

By Aug 01, 2014 11:59 PM ET, pick some or all of the following points (based on ADA’s comments) to tell FDA about.

Suggested comments for the Food Labeling docket:

  • I have had (type 1/type 2) diabetes since _____. As a person touched by diabetes, the food I eat has a direct impact on my blood sugars, and I rely on the information contained in nutrition labels on a daily basis.
  • I strongly supports FDA’s proposal to require “added sugars” be declared on the Nutrition Facts label, since these types of sugars (as opposed to sugars that occur naturally in foods) have lower nutritional value.
  • I support the FDA’s proposal to continue to require “total calories” be included on the label and to increase the prominence of the calorie declaration: sometimes this number can be very hard to find, specially considering that some people with diabetes develop complications that affect their eyesight.
  • I strongly opposed FDA’s proposal to replace “Total Carbohydrate” with “Total Carbs” on the Nutrition Facts label. Many people with diabetes use the term “Carb Choice” as a serving of food that contains 15 grams of total carbohydrate. You can see how changing these words could cause tremendous confusion!

To comment on the Proposed Nutrition Label, go to this page and click on

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Suggested comments for the Food Serving Sizes docket:

  • I have had (type 1/type 2) diabetes since _____. As a person touched by diabetes, the food I eat has a direct impact on my blood sugars, and I rely on the information contained in nutrition labels on a daily basis.
  • I support the proposed revision of the definition of a single-serving container requiring all foods packaged for individual sale containing less than 2 servings of food to be considered a single-serving container and be labeled as one serving. The easier it is to know what nutrients are within a package, the better informed the decision about the meal.
  • In terms of Dual Column Labeling options FDA presented for the content of the Nutrition Facts label for an entire container, I strongly urge FDA to require full nutrition information (carbohydrates included) per serving and per container. This is a matter of making better informed decisions about meals easier to make (requiring less math).
  • All revisions to the Nutrition Facts label and the underlying calculations used to determine the quantities presented on the labels need to be supported by an extensive consumer education campaign, to ensure they are not misunderstood by consumers as recommendations to consume larger portions. A good starting point would be visuals like the ones published by FDA, when they invited us to submit comments.

To comment on the Proposed Food Serving Sizes, go to this page and click on

Screen Shot 2014-07-22 at 5.12.31 PM

Whatever you do, don’t stay quiet.

Personally I don't really aggree with the ADA on some this, but it is important to comment to the FDA. Every comment matters.

I don't feel that added sugars have any nutritional difference to other sugars. A carb is a carb is a carb and a sugar is a sugar is a sugar (even if it is natural). So I don't support that point.

And I don't support an overemphasis on calories because I don't believe calories matter that much. And I while I don't object to the ADA getting all spun up on the confusion of carbohydrates with carbs, I don't think it is a useful point.

What I do think that has been missed is that we need to speak up on the serving size issue. For years the food industry has manipulated the serving size to artificially distort the nutrition information. It is used to make foods appear lower in carbs and to not contain transfats. I would recommend that we support the ADA position requiring that the nutrition for the entire container be reported as a serving size then the container is within 200% of a customary serving size. And further I think that the FDA should modify the reporting of transfats to not require "trace." when non-zero transfats (< 0.5 g) are present. Transfats have not been established to be safe for consumers at any level and we have a right to full disclosure of the transfat content of foods.

In the spirit of following the leaders shared during the recent MasterLab event, it makes sense to share the perspective of the American Diabetes Association (ADA) about the

They are not my leaders; I did not elect or choose them, nor do I care for the dietary advice on their website. The major change I would like to see in labeling is the elimination of 'serving size' and its replacement by nutritional content per 100 gm.

I am happy to see links to news items about various matters, this topic definitely included. I do not think that the administration of TU should attempt to tell us to 'follow the (self appointed) leader', whether the 'leader' is themselves, the ADA, or anybody else.


Pardon, ZZ:
The reference to leaders was one used during a recent meeting we held in Orlando:
The term leaders is made in reference more with "taking the lead on an issue" than "leading us" or "being our leaders".

Regardless of your thoughts about the ADA's position, please do take the time to give feedback to the FDA about this matter. It is very important that our voices be heard, even MORE so if you are in disagreement with what ADA commented.

There is undue focus on calories, prompting some to look no further. I agree as well the the serving sizes are not realistic and thus convey a false sense of security.
What I DO like however, is the actual grams declared for vitamins. That specification tells me a whole lot more than the percentage of daily values.

I've long had problems with the ADA myself, but in order to create change it is important to align efforts to provide the greatest force. So while I find most of the ADA proposal somewhat useless, it at least isn't harmful. And the serving size issue is something I totally agree with. So I'll be expressing support for the ADA position without overt criticism of anything that isn't harmful, but I will be adding my comments although I have zero expectation that will affect the current proposal. But if I keep repeating my concerns about things like transfats eventually the FDA may well listen and change things.

I still struggle with the whole idea of collaborating with organizations that I believe have goals in conflict with my own, but I am working on it.

Linda, please be sure to share your thoughts directly with FDA here (Nutrition Label Proposed Rule) and here (Serving Size Rule)!!

Most of the changes don't bother me, with the exception of the elimination of the "total calories from fat"...I used that information to determine how much/how long to dual wave my meal boluses. And although I can still get that information by looking at the total grams of fat and multiplying by 9, it just complicates that factor for me.

Will make my feelings known on the link provided.


The added sugar thing is honestly kind of silly to me, I'm not sure why it matters so much? I feel like I understand why fiber is on the label but not ever sugars. Because sugar is a carb...

The added sugar label tells you how much the manufacturer added. This would be be useful for a person, diabetic or not, who wants to eliminate excess sugar. The average person would be better off if they could eliminate the steady drip of HFCS that manufacturers seem to add to everything.

My old eyes will appreciate the larger font size.

The serving size changes are a no brainier.

Their carb position is a little silly. Do people still utilize the exchange diet??

So I agree with 3 of 4, if maybe for different reasons. This sorta surprises me:)

I have participated in the comments process for new regulations many times. If enough people share the same concern they will at least acknowledge your position and may even modify the regulation. In my experience your voice is amplified when you are aligned with a big organization like the ADA. So for this issue I like brian will be supporting the ADA.

I would like everything to be in larger print because sometimes it is so small glasses aren't enough, lol. I like the serving size to be in cups/pieces not oz or grams as it it too difficult to figure out. I don't care about calories that much. The specific content is what matters to me more, mostly carbs. I like to know what type of fat and added sugar and what type of sugar has been added. This may not apply here but I would like a much larger print of all ingredients and any chemicals the food was processed in any way with also listed in large print which is easily readable. If something is a possible carcinogen, laxative etc. I would like that mentioned also.

I find ingredients are almost always never near the nutritional labels and are often so tiny I can't see them easily. I will now be carrying a pocket magnifier. I also want to know if any artificial sweeteners are added with a special note somewhere of which one it is. I have found some labels to be very misleading such as ricola sugar free cough drops I tried last year which claimed to have no bg raising capability but which did raise me a lot due to fruit content. In their exchange info they were incorrect.

meee, did you share your feedback at the FDA link above? It's important!

A couple of thoughts on this:

  • Added Sugars - while I agree somewhat with Sensorium139 about how we look at carbs, the fact is that drawing attention to added sugars means that it will become more noticeable when companies add extra sugars to their products (assuming that added sugars include ALL forms of added sugar, such as High Fructose Corn Syrup). That being said, I do not believe that “a carb is a carb” when it comes to counting carbs. I would much rather eat 1g of carb as fiber than 1g of carb as added sugar, and I also know that the two impact my BGs much differently.
  • Serving size is really an important issue. I did not realize how much so until I started dosing insulin for carbs, and I started weighing my food for calculations. When I realized that one “serving” of Raisin Bran was such a small portion of a cereal bowl, I could not bring myself to eat it any more, even on occasion. My cereal bowl easily holds 3-4 servings of that cereal, and my bowls are not that large. Most people just don’t realize how small some of these “servings” actually are, except for those of us who have to understand it in order to manage our health.

Hi Emily,

Yes I did :) I hope they will listen!

The important thing here is that FDA hears from all of us, people with diabetes -that we provide them with loud and unquestionable input about what things we'd like to see the proposed Nutrition Labels/Serving Size changes look like. We don't have to agree with what the ADA is proposing. We should, though, make our position known through the established channels, which (in this case) is the two dockets set up for this purpose: here, for the Nutrition Label Proposed Rule ,and here for the Serving Size Rule.

I too was surprised the the "Carb Exchange" thing came up, but I am sure there's enough people still using it to warrant it.

The point about "added sugars" resonated with me, because of all that I loved about the movie FED UP: (trailer)

They do listen, meee.

See this video from Stayce Beck (FDA's lead on devices):

I agree with you meee

Thanks Manny :)