The Food and Drug Administration regulates health claims accompanying food, and its regulations are stringent. But these regulations apply only to food manufacturers. Third parties such as activist groups can make health claims without restriction.
FDA permits food manufacturers to make health claims, nutrient content claims, and claims describing the role of a nutrient or dietary ingredient affects the normal structure or function of the human body (“structure/function” claims). The informational requirements necessary to make these claims are substantial and detailed. They are so substantial and detailed that manufacturers only rarely seek to make health claims, and consumers rarely see foods labeled with health claims.
There are no such barriers to third parties that want to make health claims, however, and one way to do so is to rank alternative foods on a constructed index in which one pole is “good” and the other is “bad.”.
- Nutrition. The nutrition scoring algorithm considers multiple factors, including calories, saturated fat, trans fat, sugar, sodium, protein, fiber and fruit, vegetable and nut content.
- Ingredient concerns. The ingredient concerns algorithm focuses on factors such as the likely presence of key contaminants, pesticides, hormones and antibiotics, and the health implications of certain food additives.
- Processing. The processing score reflects EWG’s best estimate of the extent to which a particular food has been processed. Scoring factors include modification of individual ingredients from whole foods and the number of artificial ingredients.
We combine these three scores into a single overall product score. We weight a food’s nutritional value most heavily, ingredient concerns next and processing relatively lightly.
EWG’s criteria are complex, and its rating scheme is inherently subjective because it’s impossible to construct an objective index.
A few details concerning EWG’s methodology are reported on the first click-through page from the user guide, but not many. Users are encouraged to trust EWG’s method:
Our nutrition scoring algorithm is a modified version of a nutrition profiling system developed by Oxford University and the United Kingdom’s Food Standards Agency, the UK counterpart of the U.S. Food and Drug Administration. Its merit has been confirmed by peer-reviewed publications and industry researchers.
The “full nutrition methodology” is reported on a second click-through page. It consists of an external “nutrition concern algorithm” to which EWG has made adjustments on trans fat, “added versus natural sugars,” low-calorie sweeteners, “added fibers with limited data on health benefits,” and omega-3 fatty acids. EWG also made additional adjustments for “liquids, large serving sizes that deviate too far from the 100-gram standard and tiny serving sizes.”
The output of EWG’s calculator reflects its values and preferences, and those who share these values and preferences likely would find the calculator useful. To EWG’s credit, it makes it values and preferences transparent: the organization dislikes calories, saturated fat, sodium, sugar (especially added sugar), and low-calorie sweeteners. EWG also professes concern about “pesticides, hormones and antibiotics and health implications of certain food additives,” but how these attributes matter does not appear in the detailed methodology.
Others may have different values and preferences, of course, such as concern about carbohydrates other than sugar, and diabetics might not agree that low-calorie sweeteners are bad. For anyone whose values and preferences differ, the EWG methodology has limited or even negative value. That said, nothing prevents other third parties from developing competing food scoring schemes. Even food manufacturers could get into the food scoring business if they think EWG’s ratings are biased or misleading.