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7 ways to leverage the FDA Nutrition Label Update to your advantage

7 ways to leverage the FDA Nutrition Label Update to your advantage
The new Nutrition Facts label: What's different? And how can you make the most of this packaging redesign opportunity?

Follow these 7 steps to turn the required Nutrition Facts Update redesign into a consumer-pleasing recipe for packaging success.

What’s the most reproduced graphic of the past century?

Hint: It appears on more than 6.5 billion packages.

If you guessed the Nutrition Facts label, then pat yourself on the back. Now, thanks to its first redesign in more than 20 years orchestrated by the U.S. Food and Drug Administration, the label’s popularity should remain high even as its accuracy and usefulness is increased. Brand owners and their brands must comply with the new requirements by July 26, 2018, following the formal announcement on May 20.

What’s it all mean for brand owners? Helping sift through and making the most of the regulation from a packaging and package design view is Carol Best, senior vice president, client engagement, SGK.

What’s the view from brand owners?

Best:  In the years of deliberation leading up to the final ruling, many consumer packaged goods companies brands actively opposed requirements such as more realistic serving sizes, disclosure of added sugars, and other changes that could influence consumer choices. Brand owners and managers have argued that they shouldn’t be required to devote time, budget, and resources to providing information that may turn some consumers away.

Is this resistance something new?

Best: We’ve seen this opposition before. Brands also campaigned against the Nutrition Labeling and Education Act of 1990, contending that government had no business influencing consumer choices. But in the years since the original regulation took full effect in 1994, hundreds of millions of shoppers have come to rely on the Nutrition Facts label, and leading CPG brands have come around to embrace the value it adds.

What’s changed this time?

Best: There’s one important difference between then and now: While redesigning their labels in the early 1990s, few brands regarded the mandate as an opportunity to compete more effectively on the shelf. Then, as now, the new label requirements were giving consumers exactly what they want: Clear, useful information to guide nutritional choices. But today, consumers are speaking much more loudly about what they want.

We see the Nutrition Label update as an opportunity to listen to consumers and give them even more of what they want—going beyond simple compliance to deliver a real brand advantage.

Many brands have understood this trend for years and have already been adapting their labeling and communications to better address consumer needs—well in advance of regulatory mandates. Product recipes are also changing to make sure that a clear label is also a clean label. High-profile examples include the disclosure of ingredients made using genetically modified organisms by ConAgra Foods and Campbell’s; and pledges by Nestlé, General Mills, Kellogg’s, and others to eliminate artificial colors and flavorings.

It’s not only about incremental change and adaptation. Over the past decade, growing consumer demands for simplicity, sustainability, and wholesome nutrition have led to the creation of entirely new categories, have radically shaped established ones, and have even helped smaller natural and organic brands take significant market share from larger, more established brands.

Smart companies see the Nutrition Label update as a powerful signal and a rare market opportunity to create meaningful changes that consumers want to see, driving significant new growth. The entire industry must make labeling changes. The big winners will be brands that see this as a strategic opportunity, not just an imposed burden.

Best offers seven ideas to help transform the packaging redesign that you’re required to make into new opportunities to connect with consumers.

1. Look to Europe.

Brands in the European Union are leading the way, as EU Regulation 1169/2011 requires more transparent disclosure of ingredients and nutritional facts. The EU regulation goes beyond the Nutrition Facts label update, affecting front-of-package claims that could be the next target of regulation in the U.S. Learn from the brands that are most successful in turning new labeling mandates into new market opportunities.

2. Know what consumers expect from your brand.

What role does your category and brand play in the life of your consumers? These dynamics may be changing rapidly.

Does your brand provide basic nourishment or indulgence? How involved is your shopper in reading labels? Is this consistent across all channels? How do consumers think of your competition in terms of health and wellness? Are better-for-you options growing in your category? How does your brand deliver on the nutritional expectations of older and younger consumers?

Understanding consumer attitudes within your category can help you claim a position of strength against your competition and adjacent product categories.


3. Consider the implications of larger serving sizes.

Serving sizes are increasing to reflect actual consumption habits rather than the manufacturer’s suggested serving. For example, a serving of ice cream is increasing from 1/2 cup to 2/3 cup. Think about how consumers are likely to respond.

What current claims need to change? What new claims can be enabled? For example, can a low-fat claim be replaced by a high-protein claim? How can you educate retailers, shoppers and consumers through on-shelf, digital, social, and other channels? How do you compare with competitors?

Remember that small differences between products will be amplified with increased serving sizes. Think through what claims you can make and how to position your brand as a champion of transparency.

4. Identify opportunities to lead.

Use the Nutrition Facts label update as an opening for your brand to take bold, decisive action ahead of the competition. This could mean reformulating an existing product to better align with consumer expectations. It could mean repackaging your existing product to promote more responsible consumption. New product innovation could also deliver better-for-you mixes, with fewer ingredients, tapping into consumer reactions to the heightened visibility of nutritional information.

5. Understand your true design equities and assets.

The new Nutrition Facts label is in many ways bigger, bolder, and more eye-catching, yet it retains familiar design elements. To incorporate it effectively, you may need to redesign and reposition packaging artwork. What elements are required? What can you afford to change, move, or remove?

Now is the time to make these decisions – not later while in the process of building mechanical art. This is a smart time to revisit and republish your brand guidelines so these decisions are clear and well-known in advance.

6. Touch packaging only once.

Make every touch count! With all the artwork going through your internal supply chain—plus your agencies, printers, and the rest—efficiency is critical. Plan to update the Nutrition Facts label in tandem with any other changes you’ll be making. Conversely, consider what other opportunities you have to improve package design while touching the Nutrition Facts label.

The important thing is to avoid making multiple artwork changes to the same SKU within the regulatory compliance window. The same principle applies to secondary packaging, POS materials, and other brand touchpoints.

7. Assemble the right cross-functional team.

Coordinating all the components and stakeholders requires an informed, agile, experienced team. Assemble the right people now and begin planning to conduct an impact audit, define processes, assign task owners, establish governance, estimate budget requirements, and formalize success metrics.

To assess your preparedness, obtain resources and talk to SGK’s brand and label experts, visit Label Central at



As senior VP, client engagement, SGK’s Carol Best has 15 years of expertise in brand strategy and client management guiding the development and stewardship of some of the world’s most well-known brands. Prior to joining SGK, Carol worked with Interbrand (New York and Cincinnati), where she helped build a strategy department to service Procter & Gamble, and was part of the firm’s innovation team. She holds a B.S. in Economics and Marketing from The Wharton School of Business at the University of Pennsylvania. 


If you find this article of interest, also visit PD’s Food & Beverage Packaging Channel.


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