Retooling Food Standards of Identity to Address Diet-Related Chronic Disease

Abstract

Chronic disease rates have increased dramatically in the United States over the past several decades, and scientists believe that many such diseases, including heart disease and Type II diabetes, are partly attributable to dietary factors. This paper explores various ways in which the U.S. Food and Drug Administration could wield its existing statutory authority to reduce the rates of such diseases, including though enforcement of food adulteration provisions, expansion of nutritional labeling requirements, and reformulation of food standards of identity. It posits that, because they provide significant regulatory flexibility, food standards of identity are a promising means of regulating the nutrient content of foods. The paper then describes the history and structure of food standards and discusses ways in which food standards could be altered and expanded to meet nutritional goals. The FDA could promulgate standards for more foods, especially processed foods, but could make them less recipe-like in nature than most standards are currently. Such an approach would allow food manufacturers to create a wide variety of unique recipes but would allow the FDA to set forth maximum quantities of certain macronutrients or specific ingredients that are deleterious to health. Broadening the range of food standards in this way would require more stringent enforcement at the boundaries to be an effective strategy, and costs to consumers would likely increase at least marginally, but the benefits of disease reduction might outweigh those costs to both government and consumers.