Nutrition Facts Label Daily Reference Value for Added Sugars Summary of Key Findings from Consumer Message Testing Research Survey October 13, 2015 The following research summary is submitted for consideration by the Food & Drug Administration (FDA) in response to the Federal Register notice (79FR) issued July 27, 2015 (Docket No. FDA-­‐2012-­‐N-­‐1210) regarding FDA’s proposition to establish a Daily Reference Value for added sugars, and require the declaration of the percent Daily Value (%DV) for added sugars on the label. Background/Objectives: This summary highlights key findings from a consumer research survey recently conducted to understand the impact on consumers of the addition of added sugars %DV and gram amounts on the Nutrition Facts label. Specifically, the survey research is designed to measure consumers’: • Interpretation, and any potential misunderstanding of %DV information. • Interpretation, and any potential misunderstanding of the %DV and grams of added sugars. • Perceptions of the healthfulness of a product, and its usefulness for maintaining weight, with and without added sugars grams and %DV information. This research was designed, analyzed and funded by trade associations representing companies affected by the proposed revisions to the Nutrition Facts label: American Bakers Association, Corn Refiners Association, International Dairy Foods Association, National Confectioners Association and Sugar Association, Inc. Key Findings These data indicate that consumer understanding and perceptions of food products are significantly impacted by the inclusion of added sugars gram and %DV values on the Nutrition Facts label. Notably, consumers are less likely to accurately identify a product with lower total sugars and higher fiber as healthier, or a better choice for maintaining a healthy weight, when added sugars gram and %DV information are included on the nutrition facts label. • In the control label scenario without added sugars information on the label, 63% of Total Consumers, 56% of Food Assistance Consumers and 65% of Health Managers select the lower total sugars, higher fiber product as the better choice to maintain a healthy weight. • In the added sugars label scenario, consumers’ judgment appears colored by an inherent negative perception of added sugars and their choices shift significantly. Fifty-­‐
one percent of Total Consumers, 55% of Food Assistance Consumers, and 52% of Health Managers select the low fiber/higher total sugars/no added sugars product as the better choice to maintain a healthy weight because it is lower in added sugars, and is also mistakenly perceived to be lower in total sugars. •
When added sugars are included on the label, the correct choice levels decrease significantly (@ 95% confidence level), with 32% of Total Consumers, 31% of Food Assistance Consumers and 34% of Health Managers selecting the lower total sugars, higher fiber product as the better choice to maintain a healthy weight (see Fig. 2 for Total Consumer data). The pejorative image of added sugars is strong enough to impact consumer understanding and perceptions of identical food products. Consumers are less likely to accurately identify two products with identical nutrition characteristics, as equally healthy or equally helpful in maintaining a healthy weight, when added sugars gram and %DV information are included on the nutrition facts label. This suggests an inherent bias and misunderstanding around added sugars that leads consumers to characterize a product with zero added sugars, although identical in total sugars and all other nutritional characteristics, as healthier and a better choice for maintaining healthy weight. • In the control label scenario, with no information on added sugars, the 86% to 94% of Total Consumers, Food Assistance Consumers and Health Managers correctly identify both food products as equally healthy, or equally useful in helping maintain a healthy weight. • In the label scenario, where added sugars information is provided, responses shift significantly (@95% confidence level) to 52% to 62% of all three consumer groups misidentifying the zero added sugars product as a healthier choice, or a better choice for helping maintain a healthy weight (see Fig. 4 for Total Consumer data). The misinterpretation of Nutrition Facts labels that include the added sugars %DV and gram information appears to be driven by inherent, strong negative misperceptions of “added sugars.” About half of Total Consumers (48%), Food Assistance Consumers (56%) and Health Managers (51%) believe that added sugars have more calories than other types of sugars. These misperceptions appear to interfere with consumers’ ability to identify a healthier food choice that has lower levels of overall sugars and a higher level of fiber when the food is labeled as containing added sugars. Additionally, added sugars are incorrectly perceived by a majority of Total Consumers, Food Assistance Consumers and Health Managers as: • Unsafe, when consuming more than 100% of daily value (72% of Total Consumers, 73% of Food Assistance Consumers and 76% of Health Managers agree with this sentiment) • More important to limit than other types of sugars (71% of Total Consumers, 72% of Food Assistance Consumers and 74% of Health Managers agree with this sentiment) • Less healthy than sugars that occur naturally in food (71% of Total Consumers, 74% of Food Assistance Consumers and 71% of Health Managers agree with this sentiment) Consumers are already confused about the concept of % Daily Value, which may exacerbate consumer misunderstanding of the added sugars %DV information. The majority of consumers are either unsure, or incorrectly interpret the meaning of the %DV for saturated fat, a negative nutrient familiar to most consumers and taken into consideration when purchasing products • Eighty percent of consumers either agree or feel they are unsure that the %DV indicates that the food contains 10% of the daily recommended amount of saturated fat 2
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Sixty percent of consumers either agree or feel they are unsure that the %DV indicates that 10% of the total fat in this product is comprised of saturated fat Only half of consumers correctly identify the %DV as representing, “a daily limit; eating more than 100% of this limit may not be safe” Sample The quantitative on-­‐line survey was conducted by Toluna market research in October of 2015 among a sample of 2,014 U.S. adult consumers aged 18+, balanced to US Census estimates for gender, age, education, race and income. The research was conducted among three target groups: Total Consumers • 2,014 Individuals aged 18+ balanced to US Census estimates for gender, age, education, race and income. Food Assistance Consumers • 636 respondents who themselves, or have immediate family that have received assistance from any of the following programs in past year: Food stamps that help people purchase groceries (also known as SNAP -­‐ Supplemental Nutrition Assistance Program); WIC (Special supplemental nutrition program for women, infants and children); reduced-­‐price or free school meal programs that serve breakfast, lunch or after-­‐school snacks to school aged children; adult and child care food program that provide free or subsidized meals and snacks in child day care, afterschool programs and in senior adult care centers; farmers market nutrition program that provides funding for adults to buy fruits and vegetables at local farmers markets; a food bank or food pantry that distributes free groceries. Health Managers • 933 individuals currently managing any of the following health conditions by carefully selecting the foods they eat, or following a diet: heart disease, high blood pressure, diabetes or pre-­‐diabetes, overweight, obesity. Study Design With nutrition labels as stimuli, the total sample of 2014 respondents were asked questions regarding their interpretation of %DV for saturated fats and %DV for added sugars, to measure the degree to which consumers can accurately interpret this information and identify any potential misunderstanding of the %DV and grams of added sugars. The sample was split into two separate samples, each with n=1007, also balanced on gender, age, education, race and income. As Figure 1 on the next page shows, each sample was exposed to either a Control label scenario or an Added Sugars label scenario: • Control labels included %DV and gram amounts of total sugars, following the current nutrition label format. • Added Sugars labels featured proposed added sugars gram and %DV information, and total sugars g/%DV value. 3
Within each scenario, consumers were asked to evaluate and select between two food products, based on their nutrition facts label information: • Which of the two products is the healthier choice? • Which of the two products is the best choice for maintaining weight? Within each scenario, consumers also evaluated two pairs of products: • One pair of identical products which only varied in the presence or absence of added sugars • One pair of products, identical in calories, but with different levels of total fat, fiber, total sugars, and added sugars amounts – This pair included a food product with a more healthful nutrient profile signaled by the presence of higher fiber and lower total sugars (which were identified as added sugars) – The other option in this pair had a less healthful profile signaled by the presence of lower fiber and higher total sugars (none of which were added sugars) Study Design Overview (Fig.1) Control'Label'Scenario'(n=1007)'
Identical Products
Food R
Food S
Added'Sugars'Label'Scenario'(n=1007)'
Different Products
Food R
Identical Products
Food R
Food S
Food S
Different Products
Food R
Food S
Options with higher fiber and lower total sugars
6
4
Detailed Findings – Nutritionally Different Products Figure 2 shows how, for nutritionally different products, the presence of added sugars information distracts consumers from selecting the lower total sugars/higher fiber product (Food S) as the healthier choice, or as the better choice for maintaining healthy weight • Without the presence of added sugars on the label, 63% select the product with higher levels of fiber, and a lower level of total sugars; 26% of consumers select the higher levels of sugars and lower levels of fiber • With added sugars information included in the label, the choices are reversed -­‐ 51% of consumers pick the food with lower levels of fiber and higher levels of total sugars while 32% pick the lower sugars/higher fiber product. Impact of Added Sugars Information on Product Selection of Nutritionally Different Products – Healthier Choice and Better for Maintaining Healthy Weight (Fig. 2) Control$Label$Scenario$(n=1007)$
Food R
Food$R$–$16g$total$sugars,$
7g$dietary$fiber,$0g$added$
sugars,$2g$total$fat$
Food S
Added$Sugars$Label$Scenario$(n=1007)$
Food R
Food S
Food$S$–$8g$total$sugars,$
10g$dietary$fiber,$8g$
added$sugars,$3g$total$fat$
No$Added$
Sugars$Info$
Added$
Sugars$Info$
%$of$Total$Consumers$selecJng$
each$product$as$.$.$.$
The$Healthier$Choice$
Food$R$(Higher$total$sugars,$lower$fiber)$
Food$S$(Added$Sugars)$
(A)$
(B)$
33%$
53%$A$
56%$B$
32%$
26%$
51%$A$
63%$B$
32%$
Be/er$for$Maintaining$Healthy$Weight$
Food$R$(Higher$total$sugars,$lower$fiber)$
Food$S$(Added$Sugars)$
Capital letters (A, B) signify statistically significant differences @ 95% confidence level Figure 3 shows how the presence of added sugars information distracts consumers from accurately selecting Food S, the lower total sugars and higher fiber product as the better choice for maintaining a healthy weight. • In the “control” scenario, 63% of consumers select the lower sugars/higher fiber product because it is higher in fiber (61%), contains less sugars (58%), and is a good source of fiber (44%). • In the “added sugars” scenario, 51% of consumers select Food R, the low fiber/high sugars product as the better choice for maintaining weight because it has no added sugars (38%) and is mistakenly perceived as having less sugars (37%). 5
Impact of Added Sugars Information on the Reasons Why Total Consumers Selected Product as Better for Maintaining Healthy Weight – Nutritionally Different Products (Fig. 3) Control'Label'Scenario'(n=1007)'
Food R
Food'R'–"16g"total"sugars,"
7g"dietary"fiber,"0g"added"
sugars,"2g"total"fat"
Food S
Added'Sugars'Label'Scenario'(n=1007)'
Food R
Food S
Food'S'–"8g"total"sugars,"
10g"dietary"fiber,"8g"
added"sugars,"3g"total"fat"
No'Added'
Sugars'Info'
%'of'Total'Consumers'selec@ng'each'
product,'reason'for'Picking'Food'as'
BeGer'for'Maintaining'Healthy'Weight'
'
Added'
Sugars'Info'
63%"(634)"
Is"higher"in"fiber"
51%"(513)"
61%"
Is"low"in"fat"
50%"
Contains"less"sugars"
58%"
W/out"added"sugars,""
product"is"healthier"
38%"
Is"a"good"source"of"fiber"
43%"
Contains"less"sugars"
37%"
Detailed Findings – Nutritionally Identical Products Figure 4 highlights that, even in the case of nutritionally identical products, the presence of added sugars on the nutrition facts label causes consumers to misjudge the healthfulness of foods. When added sugars %DV and grams are not included on the label, 94% of consumers correctly identify the two food products as equally healthy and equally suitable for maintaining healthy weight. When added sugars information is included on the label, 57% of consumers incorrectly identify the product without added sugars as healthier. Impact of Added Sugars Information on Product Selection of Nutritionally Identical Products – Healthier Choice and Better for Maintaining Healthy Weight (Fig. 4) Control$Label$Scenario$(n=1007)$
Food R
Food$R$–%Iden?cal%to%Food%S%
except%added%sugars%are%4g%
Food S
Added$Sugars$Label$Scenario$(n=1007)$
Food R
Food S
Food$S$–%Iden?cal%to%Food%R%
except%added%sugars%are%0g%
No$Added$
Sugars$Info$
Added$
Sugars$Info$
%$of$Total$Consumers$selecLng$
each$product$as$.$.$.$
The$Healthier$Choice$
(A)%
Both%are%Equal%
Food%S%(No%Added%Sugars)%
(B)%
94%$B$
35%%
2%%
57%$A$
94%$B$
28%%
2%%
62%$A$
Be/er$for$Maintaining$Healthy$Weight$
Food%R%(Added%Sugars)%
Food%S%(No%Added%Sugars)%
Capital letters (A, B) signify statistically significant differences @ 95% confidence level 6
Figure 5 illustrates how the presence of added sugars information confounds consumers’ decision-­‐
making process, even in the case of nutritionally identical products. In the added sugars label scenario, the perception of Food S is transformed by the presence of the added sugars line. Although nutritionally identical, with the same amount of total sugars, 62% of consumers select Food S as the better product for maintaining a healthy weight because they believe that: without added sugars the product is healthier (50%), the product contains less sugars (33%) and it has no grams of added sugars (41%). Impact of Added Sugars Information on the Reasons Why Total Consumers Selected Product as Better for Maintaining Healthy Weight – Nutritionally Identical Products (Fig. 5) Control'Label'Scenario'(n=1007)'
Food'R'–#Iden.cal#to#Food#S#
except#added#sugars#are#4g#
Food R
Food S
Added'Sugars'Label'Scenario'(n=1007)'
Food R
Food S
Food'S'–#Iden.cal#to#Food#R#
except#added#sugars#are#0g#
No'Added'
Sugars'Info'
%'of'Total'Consumers'selec>ng'each'
product,'reason'for'Picking'Food'as'
BeFer'for'Maintaining'Healthy'Weight'
'
Added'
Sugars'Info'
62%#(624)#
2%#(20)#
Is#higher#in#fiber#
48%#
W/out#added#sugars#product#is#
healthier#
50%##
%DV#added#sugars#is#zero#
43%#
Contains#less#sugars#
33%#
Is#a#good#source#of#fiber#
43%#
Has#no#grams#of#added#sugars#
41%#
7