4.4 Article

Digging up the dirt on clean dietary labels: Public health considerations and opportunities for increased Federal oversight

Journal

INTERNATIONAL JOURNAL OF EATING DISORDERS
Volume 55, Issue 1, Pages 39-48

Publisher

WILEY
DOI: 10.1002/eat.23585

Keywords

clean eating; clean labeling; diet trend; FDA; litigation; regulation

Funding

  1. Ellen Feldberg Gordon Fund for Eating Disorders Prevention Research
  2. Strategic Training Initiative for the Prevention of Eating Disorders
  3. Maternal and Child Health Bureau, Health Resources and Services Administration, U.S. Department of Health and Human Services [T76-MC-00001]
  4. Research and Development Committee, Dickinson College

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The clean diet trend is popular among consumers, but there is a lack of consensus on its definition and regulation in the United States. Regulatory efforts need to be strengthened to prevent potential harm to public health from misleading clean labeling claims.
Background Clean dietary labels are often viewed by consumers as referencing products that are minimally processed, without additives, preservatives, artificial colors, or ingredients, but may also be interpreted as vegan, gluten-free, dairy-free, real, or natural. Although the clean diet trend continues to grow in popularity, there is a lack of consensus regarding the definition and use of this terminology with a corresponding lack of regulation for such labels in the United States. Method This multidisciplinary scoping review examines the public health implications of the clean label trend and the legal and policy landscape for regulation. We report on findings from case law and legal research generated through the Westlaw database and from the U.S. Food and Drug Administration (FDA) enforcement actions and website documents to discuss options for federal- and state-level intervention to mitigate harm. Results One feasible avenue for change is for the FDA to provide industry guidance, disseminate public statements to debunk myths, and enforce labeling statutes to police deceptive clean labeling claims. We also suggest consumer-protection litigation and state-level litigation via attorneys general as alternative actions to combat the abundant misinformation associated with clean diets and labels. Discussion Although the FDA has taken some enforcement actions, these efforts are insufficient given the proliferation of clean label products in the marketplace and the potential for adverse impacts on public health including increased risk for disordered eating. The current unregulated, undefined landscape for clean dietary labels thus requires urgent action by federal authorities and state attorneys general.

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