Front of Package Labeling is Coming

In January 2025, the FDA issued a proposed rule on front-of package (FOP) nutrition labeling intended to help consumers quickly and easily identify how foods can be part of a healthy diet.
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The Impact of Fop Labels on Suppliers and Manufacturers

By Michelle Briffett, Principal, Roland Berger

The prevalence of obesity has surpassed that of malnutrition globally, with approximately one in eight people living with obesity compared to one in 10 with malnutrition. In advanced economies, obesity is an even bigger issue, affecting more than 40% of adults in the United States, for instance.

Obesity may be the most widespread diet-related disease, but numerous others, including diabetes and cardiovascular diseases, are also increasing. Despite this, consumers now have more access to nutrition information than ever before, thanks to detailed nutrition labeling requirements and the internet.

There is extensive data available on the back-of-package nutrition facts of packaged foods and beverages, but most consumers find it time-consuming to process all the information while shopping. Recognizing these limitations, regulators are increasingly taking a proactive approach to improving public health. In 2009, South Korea became the first country to introduce front-of-pack nutrition labels to provide consumers with simpler and more immediate nutrition information. Since then, many countries have followed suit.

Early Impacts of Front-of-Package Labeling

Front-of-package nutrition labels can be broadly classified into repeated systems, warning systems and spectrum systems. South Korea’s labels fall under the repeated system category, which repeats key nutrition information from the back-of-package onto the front-of-package. Warning systems display warnings about high levels of certain nutritional elements, while spectrum systems display a singular letter or numerical grade of a product’s healthiness based on a mathematical formula.

Front-of-package nutrition labels have been shown to have an impact on consumer health. In 2016, Chile implemented a multi-pronged obesity reduction program that combined front-of-package warning labels with marketing restrictions, school-based restrictions and taxation. A study published in the Lancet in 2021 examined the effects of Chile’s multi-pronged program by analyzing purchase data from a sample of the population. The study compared data from 18 months before and after the program’s implementation. It revealed a 3.5% reduction in calorie intake, as well as reductions of 10.2%, 4.7% and 3.9% in sugar, sodium and saturated fat consumption, respectively.

The researchers also observed changes in consumer behavior within specific food categories. For instance, consumption of industrialized fruit and vegetable juices with warning labels decreased by 47%, while purchases of meat substitutes with warning labels declined by 11%. However, overall consumption within each category remained relatively stable as consumers predominantly switched to products within the same category that did not bear warning labels.

While obesity rates have continued to rise in Chile after the implementation of the multi-pronged obesity reduction program, policymakers consider it an early success story in the adoption of front-of-package nutrition labels. Currently, both the United States and the European Union are in different stages of implementing mandatory front-of-pack nutrition labels. Several EU member states have already adopted NutriScore, a voluntary spectrum system. However, there is controversy surrounding a potential EU-wide implementation, as many Southern European member states see it as placing traditional foods at a disadvantage.

In the United States, extensive research has been conducted on various front-of-package nutrition labels. The FDA submitted its proposed FOP labeling approach to the Office of Management and Budget in November 2024 and published the rule publicly in January 2025. The FDA has proposed that most packaged foods display a Nutrition Info box that discloses whether the product is high, medium, or low in sodium, added sugars and saturated fats per serving. The percentage of recommended daily intake for each of these nutritional elements will also be listed.

Image courtesy of FDA.gov

The FDA’s proposed front-of-package (FOP) nutrition label is referred to as the nutrition info box. It would complement the nutrition facts label that is required on most food packages. The label displays simplified, at-a-glance, nutrition information that details and interprets the saturated fat, sodium, and added sugar content of a food as “Low,” “Med,” or “High” on the front of food packages. It is intended to provide consumers with an accessible description of the numerical information found in the Nutrition Facts label.

Comments on the proposed FDA rule can be submitted electronically on http://www.regulations.gov by May 16, 2025. Find additional resources and information about the proposed FDA rule at: https://www.fda.gov/food/nutrition-food-labeling-and-critical-foods/front-package-nutrition-labeling

Changes for Suppliers and Manufacturers

Making this transition to FOP labels in the U.S. will result in marketplace changes. Certain product categories are likely to be impacted more than others, with some products coming out as winners and others as losers. Each labeling system will have different impacts on consumer behavior. Packaged food and beverage manufacturers will have to decide whether to reformulate their products and if so, whether to do so on a global or regional level.

Additionally, these players might explore opportunities to streamline their product offerings (SKUs) or introduce nutritionally optimized products. Food ingredient companies can assist in reformulations by offering solutions for reducing sugar, fat and salt content. Retailers have opportunities to optimize their shelf-space to prioritize products with better nutritional profiles.

While final direction under the incoming administration remains to be seen, the anticipation is that the FDA will move forward with FOP label regulations. The time is now for manufacturers and suppliers to assess how FOP labels will impact their business and develop proactive strategies.

About the Author

Michelle Briffett is a Principal for global consultancy Roland Berger. With more than 10 years of international consulting experience, she has helped clients tackle strategic challenges, enter new growth sectors, complete complex M&A deals and transform their businesses. Michelle is dedicated to serving clients in the food and specialty chemicals industries. Michelle received her Honors in Business Administration from Ivey Business School and her MBA from London Business School. Learn more at https://www.rolandberger.com/en/.