We respectfully submit this letter as a comment to the Food and Drug Administration’s (FDA’s) “Comprehensive, Multi-Year Nutrition Innovation Strategy.” Overall, we appreciate the agency’s commitment to align food labels with dietary advice.

The stakes are high: roughly 72 percent of adults and 35 percent of children and teens are now overweight or obese. Approximately 45 percent of adults now have diabetes or prediabetes. Every time a consumer is looking for healthier food and instead is sold a food or beverage that undermines their health, that is a missed opportunity to reduce diet-related disease.

Consumers do pay attention to labels: studies show that more than half of consumers look at the nutrition facts panel or ingredient list “often” or “always” when making a purchasing decision, while 40 percent consider other labeling statements about health or nutrition benefits.

Contrary to the sound recommendations of the 2015 Dietary Guidelines for Americans, Americans under-consume healthful foods: in particular, fruits and vegetables, low-fat dairy, and whole grains. We also over-consume unhealthful added sugars, saturated fats, and sodium.

It is therefore critical that FDA’s initiative seeks to correct misleading or inaccurate labeling claims on unhealthful foods and does not enable such foods to unfairly compete even more readily with fruits and vegetables and other healthful options.

For the full letter, click here.