The definition of “healthy” is often arbitrary and changes frequently. However, consumer goods companies covet the term “healthy” as it has appeal to shoppers looking to make healthful choices. So what can be labeled as healthy? 

The current definition of healthy, as it applies to nutrient content claims on product labels in the United States, was established in 1994. Created based on federal nutrition guidelines and scientific studies during the time, the definition is centered around defining the minimum and maximum allowances of individual nutrients such as proteins, fats, carbohydrates (sugars, dietary fiber), vitamins, and minerals.

The FDA recently proposed a new rule, which it says is based on current science and guidelines, that defines “healthy” claims along two parameters. First, the product in question would need to contain a certain amount of a food group such as fruits, vegetables, grains, proteins, and dairy. Second, it would also be barred from containing too much sodium, added sugars, or saturated fats.

“To make healthier food choices for yourself and your family, aim to eat a variety of vegetables, fruits, whole grains, lower-fat dairy, protein foods, and healthy oils—like olive and canola,” Susan Mayne, PhD, director of FDA’s Center for Food Safety and Applied Nutrition, said in a statement. “Try to eat and drink fewer foods and beverages high in saturated fat, sodium, or added sugars.”



The reason why the FDA is seeking to update “healthy” claims, according to the organization, is to empower people to build a dietary pattern that helps them reduce chronic diseases related to diet. In crafting its proposed definition, the FDA acknowledges that non-Hispanic Black Americans are at a disproportionate risk for developing diet-related diseases such as Heart disease, type 2 diabetes, certain cancers, and obesity—among the leading causes of death and disability in the United States.

Are eggs, dairy, and meat healthy?

This week, the Physicians Committee for Responsible Medicine (PCRM)—a nonprofit with 17,000 doctor members—submitted a complaint to FDA Commissioner Robert M. Califf, MD, to challenge the proposed rule.  

In its complaint, Anna Herby, DHSc, RD, CDE, nutrition education program manager for PCRM, explains that the FDA’s rule makes certain accommodations to fit foods into its new definition of healthy. For instance, the rule proposes an upper limit of five percent daily value (DV) of saturated fat per reference amount customarily consumed (RACC) for a food to be considered healthy. However, the FDA adjusts that baseline to 10 percent DV per RACC to allow for dairy, meat, and eggs to fit into the “healthy” claim. 

“The proposed rule should not be making special accommodations for the sale and marketing of harmful foods such as eggs, dairy, and meat as ‘healthy.’ Besides being the predominate sources of saturated fat in American’s diets, the consumption of these foods poses other significant health risks,” the complaint states.

When it comes to eggs, Herby explains that 60 percent of their calories come from saturated fat, which, combined with their lack of fiber, does not substantiate a “healthy” claim. The proposed rule also ignores the detrimental role of cholesterol (which is only found in animal-derived foods) to heart health—a fact the egg industry, according to PCRM, has been attempting to downplay in recent years. 

Allowing dairy to carry healthy claims is also dubious, PCRM notes, as its consumption has been linked to numerous health issues. For instance, a study published earlier this year found that men who regularly consume dairy, particularly milk, compared to those who abstain from it, could be at approximately a 60-percent higher risk of developing prostate cancer. 



Women who consume dairy also put themselves at higher risk for breast cancer, with those who drink two to three cups per day increasing risk up to 80 percent, according to a 2020 study. Allowing dairy products to carry healthy claims also comes with additional negative effects.

“Since the proposed rule specifically highlights how diet-related diseases are disproportionately affecting people of color, making accommodations to allow dairy products to be marketed as ‘healthy’ would only exacerbate health disparities in this country,” the complaint states. 

The case for plant-based foods 

Since the 1994 definition of “healthy” was developed, the scientific community has uncovered many new insights about how plant-based versus animal-derived foods. For one, PCRM cited 20 recent studies in its complaint that support its claims which link the consumption of animal products to illnesses such as heart disease, type 2 diabetes, and certain cancers. 



The studies referenced also demonstrate growing research in how a plant-based diet can benefit human health and lower the risk factors for the diet-related illnesses the FDA is trying to thwart with its proposed definition of “healthy.” 

“Limiting saturated fat and cholesterol should be paramount for the ‘healthy’ label,” Herby said in a statement. “Truly healthy foods, like fruits, vegetables, grains, and beans, are low or in saturated fat and cholesterol and have been shown to help prevent and reverse heart disease, as well as diabetes, high blood pressure, stroke, and cancer.”

In its proposed rule, the FDA claims that it makes certain exceptions for saturated fat and cholesterol to promote the consumption of certain animal products due to the other nutrients they provide such as choline, vitamin D, and essential fatty acids. However, in its complaint, PCRM points out that these nutrients are all available through plant-based foods or other non-animal sources. 

Choline can be abstained by consuming tofu, soy milk, cruciferous vegetables, beans, quinoa, and peanut butter. “Furthermore, overt choline deficiency is rare, possibly due to the body’s endogenous production of the vitamin,” the complaint states. Plant-based foods such as flax seed, chia seeds, and walnuts contain 14 essential fatty acids. And a major cause of vitamin D deficiency is a lack of sunlight which PCRM suggests can be remediated through lifestyle changes as opposed to consuming foods with saturated fats and cholesterol.  


“Nutrients of concern can be found in other sources without compromising saturated fat or cholesterol limits. The Physicians Committee encourages the final rule to remove the special  accommodations for saturated fat for eggs, meat, and dairy. The final rule should instead limit foods high in saturated fat equally and promote the consumption of fruits, vegetables, legumes, and grains that are low in saturated fat and high in fiber and other nutrients.”

The FDA is accepting comments on its proposed rule until February 16, 2023. 

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