Breaking Down the New Nutrition Facts Rules - Part 2 of 3
Breaking Down the New Nutrition Facts Rules
Part 2: Vitamins
Posted by Dan Berg, Food Scientist, Analytical Services Manager
This is part 2 of a 3 part series on tips to consider for the New Nutrition Facts and Dietary Supplement Rules, published in 2016, and now in compliance in 2020. If you missed part 1, it’s linked HERE. In this part, we will take a deep dive into the changes on vitamins that we get the most questions on.
Rebalance your multi-vitamin
Every single one of the vitamins had a change in their Daily Value (DV) as directed by current information from the National Academy of Medicine (formerly Institute of Medicine). Due to the change in DVs, that multivitamin which was labeled with 100% of the DV for a dozen or so vitamins and minerals in the past may contain between 50-1000% DV using the new rules if you didn’t reformulate. The same goes for fortified cereals and functional beverages. All thirty nutrients have a new daily value content, two of which: added sugar and choline, are completely new. With changes in the units of measure, conversion factors, and actual daily value contents, there are many factors to consider in reformulation or making claim adjustments.
Adjust your Vitamin A
With the new Daily Values (DV) and units of measure (UoM), those golden carrots are losing some of its luster. If you were making a claim of Vitamin A content from natural fruit or vegetable sources, your claim will likely decrease significantly. Vitamin A is now measured in Retinol Activity Equivalents (RAE), with 1 mcg of retinol equal to 1 mcg RAE, while beta-carotene has an equivalence of 12 mcg beta-carotene to 1 mcg RAE. This is a big departure from the IU conversion factors. In the past, 1 cup of whole milk and 1 cup of tomato soup both had about 400 IU and that calculated to 8% daily value for Vitamin A. But with RAE, 1 cup whole milk’s 112 mcg RAE increases to 12% and would round to 10% DV. While a cup of tomato soup’s 20 mcg RAE is just 2% DV. With Vitamin A being optional and no longer mandatory, many foods may be dropping their declared content. Keep in mind that supplemental beta-carotene has half the potency of retinol, so if this is used for vitamin claims, that conversion factor should be used.
Dealing with Vitamin D
Vitamin D is the new mandatory vitamin, and there is solid evidence that a higher level in our diet will lead to health benefits. Although Vitamin D needs to be declared, if your product isn’t fortified or contain one of a few natural sources: meats, fish, dairy, or some yeast and fungi exposed to sunlight or irradiation, your product won’t contain Vitamin D and you can save the expense of testing and simply state “not a significant source of Vitamin D” on your label. Look for potential new fortification routes as public health and industry balance strategies to increase D in our diets.
Evaluate your source of Vitamin E
Do you know if your source of Vitamin E is natural or synthetic? Don’t let the names fool you. Alpha-Tocopherol, Tocopheryl acetate, and Tocopheryl succinate can all be natural or synthetic. Tocopherol can be esterified to improve its stability, but it’s the source of that tocopherol that makes the difference if it’s natural or synthetic for the purpose of label potency.
Natural products will state d-alpha or RRR- form, while its synthetic counterparts are referred to as dl-alpha or all-rac (all racemic). Mixed tocopherols and tocotrienols have value for their antioxidant properties and potentially other health benefits, but only the alpha form should be included in vitamin content calculations. With the new conversion factors, there may be a reason to review the economics of using natural or synthetic sources as the potency advantage of natural went from 1.49 to 2X that of synthetic.
Refactor your Folic Acid and Folates
FDA implemented a number of changes to align with the current understanding of nutritional science. Among this is the use of Dietary Folate Equivalents (DFE) to account for the differences in bioavailability of synthetic folic acid compared to natural folates in foods.
Changes like this complicate existing data on our diets, such as the USDA National Nutrient Database and NHANES survey, where historical data did not account for any difference. Fortunately for the food industry, the declared contents will either remain unchanged (from natural folates) or increase in allowable declaration (from synthetic folic acid) from the same level of fortification. Pay close attention to the methods of analysis chosen and how results are reported so that a proper calculation to DFE units can be made.
In the final part of this 3 part series, we will cover some related topics to the Nutrition Facts rule changes.
With many changes on the horizon, Eurofins experts are available to provide advice on testing programs and how to properly calculate your nutrient declarations that align with the new regulations.
References
Changes to the Nutrition Facts Label https://www.fda.gov/food/food-labeling-nutrition/changes-nutrition-facts-label
Industry Resources on the Changes to the Nutrition Facts Label https://www.fda.gov/food/food-labeling-nutrition/industry-resources-changes-nutrition-facts-label
