FDA gives a 20% leeway for accuracy on nutrition labels.

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  • lemurcat12
    lemurcat12 Posts: 30,886 Member
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    It's not nearly as excusable to get it that wrong on packaged foods from a plant as restaurant foods.

    It's not necessarily getting it wrong, it's inherent variability.
  • hookilau
    hookilau Posts: 3,134 Member
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    This just in, man lands on moon!!

    :laugh:
  • Meerataila
    Meerataila Posts: 1,885 Member
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    I doubt very much the calorie variation in two equal weight vegetables differs a fraction as much as two hamburger patties that are %20 different. In fact, I'm quite sure of it. That said, nutrients come from soil and soil quality varies, so it's probably hit or miss when it comes to vitamins and minerals.

    Your doubt doesn't qualify as fact. You may wish to look into it. I posted the results of a research paper above which had a fruit where the calorie content of a typical fruit would be +/- 25% the calories of the average fruit. And, the total range of variation in calorie content spanned two orders of magnitude (the highest calories by g was almost 100 times the lowest calories by g -- although those values were outliers).

    So... if two patties have a 20% difference in calories, a fruit or vegetable with a 25% difference from the average could easily outstrip it. If you're trying to back out of your words by saying 100g of apple that have 13 more calories as expected is a smaller error than 100g of ground beef that has 40 calories more than the label says, you're only partially correct. Because of nutrient density, a smaller error in ground beef results in a larger amount of calories. If you hold the calories constant, the error for the apples would be larger. Apples: +/- 25 calories per 100 calories, Ground Beef: +/- 20 calories per 100 calories (using your 20% difference figure).

    And, yeah, the vitamins and minerals is hugely variable. It's not just the soil. It is related to dozens of factors on top of that.

    So worst case scenario with two fruits of equal size is that there is a %25 variation. However, that brings up the question: Does something like a pasta dish vary in flour calories and sauce from lot to lot, too? If so, it could compound the problem, resulting in a worst case scenario of %45 off. %25 ingredient variation and then %20 portion size variation. Unless that is somehow prevented in packaged and restaurant foods when it is not in the produce section?

    Darned if I know. I'm surprised it varies that much in produce. It's a wonder any of us lose weight counting calories at all!
  • nitrospop
    nitrospop Posts: 122 Member
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    Did you know that 90% of all statistics are made up on the spot?
  • nopotofgold
    nopotofgold Posts: 164 Member
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    I was just reading some f these replies and what I got out of it is you can't trust anything. If the natural food is an average the the weight is an average. Maybe this is why diet and exercise are the winning team in weight lose.
  • FIT_Goat
    FIT_Goat Posts: 4,224 Member
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    So worst case scenario with two fruits of equal size is that there is a %25 variation. However, that brings up the question: Does something like a pasta dish vary in flour calories and sauce from lot to lot, too? If so, it could compound the problem, resulting in a worst case scenario of %45 off. %25 ingredient variation and then %20 portion size variation. Unless that is somehow prevented in packaged and restaurant foods when it is not in the produce section?

    Darned if I know. I'm surprised it varies that much in produce. It's a wonder any of us lose weight counting calories at all!

    I don't know if that is the worst case scenario. It is specific to each fruit. But, I would say that 20% is a safe default assumption. You don't need to go with 25%. It's just not as certain as you would think.

    Also, random errors don't add. The formula for figuring out the total error is sqrt( err_1^2 + err_2^2 + ... + err_n^2 ). So, say I have 3 components (all with a 20% error) of the following calories: 100, 250, 85. That would be sqrt( 20^2 + 50^2 + 17^2 ) or 56.47 calories... or roughly 13% error. And, if you're weighing your food out, the portion variation should be roughly related to the precision of your tool (if you weigh in g then it would be +/- 1g / serving_g.... say a 28g serving... it would be +/- 3.6%).
  • Meerataila
    Meerataila Posts: 1,885 Member
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    So worst case scenario with two fruits of equal size is that there is a %25 variation. However, that brings up the question: Does something like a pasta dish vary in flour calories and sauce from lot to lot, too? If so, it could compound the problem, resulting in a worst case scenario of %45 off. %25 ingredient variation and then %20 portion size variation. Unless that is somehow prevented in packaged and restaurant foods when it is not in the produce section?

    Darned if I know. I'm surprised it varies that much in produce. It's a wonder any of us lose weight counting calories at all!

    I don't know if that is the worst case scenario. It is specific to each fruit. But, I would say that 20% is a safe default assumption. You don't need to go with 25%. It's just not as certain as you would think.

    Also, random errors don't add. The formula for figuring out the total error is sqrt( err_1^2 + err_2^2 + ... + err_n^2 ). So, say I have 3 components (all with a 20% error) of the following calories: 100, 250, 85. That would be sqrt( 20^2 + 50^2 + 17^2 ) or 56.47 calories... or roughly 13% error. And, if you're weighing your food out, the portion variation should be roughly related to the precision of your tool (if you weigh in g then it would be +/- 1g / serving_g.... say a 28g serving... it would be +/- 3.6%).

    Ah, okay. Thanks. But in the end, then, the best we can do is weigh everything and just deal with the rest. How irritating!
  • FIT_Goat
    FIT_Goat Posts: 4,224 Member
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    Ah, okay. Thanks. But in the end, then, the best we can do is weigh everything and just deal with the rest. How irritating!

    Yeah, it is especially irritating when you're trying to get a best estimate for your TDEE based on calories in (which are full of error) and change in weight (tons of error in weight measurements). But, that's all we have to work with (unless you have access to really high tech labs that will analyze everything for you).

    All that said, the long term averages (average daily intake for week+ lengths of time & average daily weight for week+ lengths of time) tend to be reasonably good approximations of the actual values. If anything, it helps one learn to relax about daily ups and downs on the scale and minor (hopefully rare) swings above your calorie goals. In the big picture, both of those are easily dwarfed by the errors we can't control. As long as the long term numbers are going in the right direction, keep doing what you're doing.
  • WildcatDeLalune
    WildcatDeLalune Posts: 74 Member
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    Many of the nutrition labels are based on diet amounts of 2000 or 2500 calories. If you are not consuming these amounts then your numbers are going to be off anyway.

    The calories contained in an item do not change based on the consumer's caloric needs.

    If this is the case then why even place any specific amounts on the label?

    I believe you're referring to the Percent Daily Values. Those are the numbers linked with the recommended / average 2,000 calorie diet.
  • Mr_Knight
    Mr_Knight Posts: 9,532 Member
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    The 20% difference is actually referring to what restaraunts say is in their food.

    And its not so much that they allow 20% and above that they dont allow. Its that they take these companies at their word, and in one study it was shown to be up to 20% more than what was listed.

    ^This.
    There is no official leeway.

    That is incorrect.

    The labelling requirements specifically spell out allowances for variation, and that allowance is allowed to be as large as the manufacturer wants it to be, so long as there is "high probablity" that the value printed on the label will be met or exceeded. IE, all errors are on the side of under-reporting calories.

    In addition, 20% is explicitly defined by the FDA as a the "leeway" for a wide variety of nutrient data.

    The implication is that those eating primarily packaged foods are almost certainly consuming more than they think they are - possibly significantly more.

    And it's all within the rules....
  • Mr_Knight
    Mr_Knight Posts: 9,532 Member
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    I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

    That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

    This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.
  • FIT_Goat
    FIT_Goat Posts: 4,224 Member
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    I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

    That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

    This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.

    Source?
  • FIT_Goat
    FIT_Goat Posts: 4,224 Member
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    This is from the government guide to food labeling: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=101.9
    (1) "Calories, total," "Total calories," or "Calories": A statement of the caloric content per serving, expressed to the nearest 5-calorie increment up to and including 50 calories, and 10-calorie increment above 50 calories, except that amounts less than 5 calories may be expressed as zero. Energy content per serving may also be expressed in kilojoule units, added in parentheses immediately following the statement of the caloric content.

    (i) Caloric content may be calculated by the following methods. Where either specific or general food factors are used, the factors shall be applied to the actual amount (i.e., before rounding) of food components (e.g., fat, carbohydrate, protein, or ingredients with specific food factors) present per serving.

    (A) Using specific Atwater factors (i. e., the Atwater method) given in Table 13, "Energy Value of Foods--Basis and Derivation," by A. L. Merrill and B. K. Watt, United States Department of Agriculture (USDA) Handbook No. 74 (slightly revised, 1973), which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 and is available from the Office of Nutritional Products, Labeling and Dietary Supplements (HFS-800), Center for Food Safety and Applied Nutrition, Food and Drug Administration, 5100 Paint Branch Pkwy., College Park, MD 20740, or may be inspected at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to:http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. ;

    (B) Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9-11, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section);

    (C) Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate less the amount of insoluble dietary fiber, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9-11, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section;

    (D) Using data for specific food factors for particular foods or ingredients approved by the Food and Drug Administration (FDA) and provided in parts 172 or 184 of this chapter, or by other means, as appropriate; or

    (E) Using bomb calorimetry data subtracting 1.25 calories per gram protein to correct for incomplete digestibility, as described in USDA Handbook No. 74 (slightly revised 1973) p. 10, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section).

    Which part of the above declares that they always round up and with an error margin of 20%? The rounding should be done in 5 or 10 calorie increments and be based on the unrounded macro calculations (or one of the other methods outlined). I haven't dug through the specifics of each... perhaps you have and can point the way.
  • auddii
    auddii Posts: 15,357 Member
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    I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

    That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

    This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.

    Source?

    http://www.fda.gov/food/guidanceregulation/guidancedocumentsregulatoryinformation/labelingnutrition/ucm063113.htm

    From the above manual:
    n order to evaluate the accuracy of nutrition label information against a standard for compliance purposes, FDA regulations define two nutrient classes (Class I and Class II) (21 CFR 101.9(g)(3)) and list a third group (Third Group) of nutrients (21 CFR 101.9(g)(5)). Class I nutrients are those added in fortified or fabricated foods. These nutrients are vitamins, minerals, protein, dietary fiber, or potassium. Class I nutrients must be present at 100% or more of the value declared on the label ; in other words, the nutrient content identified by the laboratory analysis must be at least equal to the label value. For example, if vitamin C is added in a fortified product and the label states that vitamin C is present at 10% Daily Value (DV), the laboratory value must equal at least 6 mg of vitamin C/serving (i.e., 10% of the 60 mg Reference Daily Intake (RDI) for vitamin C that is specified in 21 CFR 101.9(c)(8)(iv)). The ratio between a laboratory finding of 4.8 mg vitamin C/serving (i.e., 8% DV) and the label value of 10% DV would be calculated as follows:

    (8% / 10%) x 100 = 80% or (4.8 mg / 6 mg) x 100 = 80%

    and the label value would not be in compliance.

    Class II nutrients are vitamins, minerals, protein, total carbohydrate, dietary fiber, other carbohydrate, polyunsaturated and monounsaturated fat, or potassium that occur naturally in a food product. Class II nutrients must be present at 80% or more of the value declared on the label. As an example: If vitamin C is a naturally occurring nutrient in a product, and the product declares 10% DV vitamin C (i.e., 6 mg/serving) on its label, then laboratory analysis must find at least 80% of the label value (80% of 6 mg or 4.8 mg vitamin C/serving) for the product to be in compliance.

    The Third Group nutrients include calories, sugars, total fat, saturated fat, cholesterol, and sodium. However, for products (e.g., fruit drinks, juices, and confectioneries) with a sugars content of 90 percent or more of total carbohydrate, to prevent labeling anomalies due in part to rounding, FDA treats total carbohydrate as a Third Group nutrient instead of a Class II nutrient. For foods with label declarations of Third Group nutrients, the ratio between the amount obtained by laboratory analysis and the amount declared on the product label in the Nutrition Facts panel must be 120% or less, i.e., the label is considered to be out of compliance if the nutrient content of a composite of the product is greater than 20% above the value declared on the label. For example, if a laboratory analysis found 8 g of total fat/serving in a product that stated that it contained 6 g of total fat/serving, the ratio between the laboratory value and the label value would be (8 / 6) x 100 = 133%, and the product label would be considered to be out of compliance.

    Reasonable excesses of class I and II nutrients above labeled amounts and reasonable deficiencies of the Third Group nutrients are usually considered acceptable by the agency within good manufacturing practices.
  • auddii
    auddii Posts: 15,357 Member
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    This is from the government guide to food labeling: http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfrsearch.cfm?fr=101.9
    (1) "Calories, total," "Total calories," or "Calories": A statement of the caloric content per serving, expressed to the nearest 5-calorie increment up to and including 50 calories, and 10-calorie increment above 50 calories, except that amounts less than 5 calories may be expressed as zero. Energy content per serving may also be expressed in kilojoule units, added in parentheses immediately following the statement of the caloric content.

    (i) Caloric content may be calculated by the following methods. Where either specific or general food factors are used, the factors shall be applied to the actual amount (i.e., before rounding) of food components (e.g., fat, carbohydrate, protein, or ingredients with specific food factors) present per serving.

    (A) Using specific Atwater factors (i. e., the Atwater method) given in Table 13, "Energy Value of Foods--Basis and Derivation," by A. L. Merrill and B. K. Watt, United States Department of Agriculture (USDA) Handbook No. 74 (slightly revised, 1973), which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 and is available from the Office of Nutritional Products, Labeling and Dietary Supplements (HFS-800), Center for Food Safety and Applied Nutrition, Food and Drug Administration, 5100 Paint Branch Pkwy., College Park, MD 20740, or may be inspected at the National Archives and Records Administration (NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to:http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html. ;

    (B) Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9-11, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section);

    (C) Using the general factors of 4, 4, and 9 calories per gram for protein, total carbohydrate less the amount of insoluble dietary fiber, and total fat, respectively, as described in USDA Handbook No. 74 (slightly revised 1973) pp. 9-11, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section;

    (D) Using data for specific food factors for particular foods or ingredients approved by the Food and Drug Administration (FDA) and provided in parts 172 or 184 of this chapter, or by other means, as appropriate; or

    (E) Using bomb calorimetry data subtracting 1.25 calories per gram protein to correct for incomplete digestibility, as described in USDA Handbook No. 74 (slightly revised 1973) p. 10, which is incorporated by reference in accordance with 5 U.S.C. 552(a) and 1 CFR part 51 (the availability of this incorporation by reference is given in paragraph (c)(1)(i)(A) of this section).

    Which part of the above declares that they always round up and with an error margin of 20%? The rounding should be done in 5 or 10 calorie increments and be based on the unrounded macro calculations (or one of the other methods outlined). I haven't dug through the specifics of each... perhaps you have and can point the way.
    It helps if you cite the correct section, not something randomly. See above.
  • Jess__I__Can
    Jess__I__Can Posts: 307 Member
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    ETA: Nevermind.
  • Alice_in_VVonderland
    Alice_in_VVonderland Posts: 67 Member
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    This is crazy.

    As a consumer, I honestly thought that companies like that paid to have those tests done. I mean, if you're in the business of food, you should be all up in the business of your food.

    I DO understand minor discrepancies due to the human factor. I used to work fast food, and we had to weigh things to make sure we were on target. Depending on the person making the food, (and I kid you not, depending on the size of their hands) some foods could weigh up to 20% more than target weight. Sometimes that weight was extra lettuce or tomato, but other times that extra weight is cheese or sauce.

    I think this just reinforces the idea that eating out should be done as a rare treat, and not as an every day habit.
  • Mr_Knight
    Mr_Knight Posts: 9,532 Member
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    I agree its helpful to KNOW there is a margin of error. However, to put a number on it that is not entirely accurate could causeThat person would be misunderstanding the numbers. The calories can be as much as 20% higher or lower.

    That is also incorrect. The FDA specifically mandates a one-sided variance, meaning the actual numbers are almost always HIGHER than labelled, and almost never LOWER than labelled.

    This is an intentional policy decision, designed to protect consumers from getting less than they believe they paid for.

    Source?

    FDA's food labelling "textbook".
  • Mr_Knight
    Mr_Knight Posts: 9,532 Member
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    I think this just reinforces the idea that eating out should be done as a rare treat, and not as an every day habit.

    For someone counting close, running small deficits? Yep, that's about right. The error bars on restaurant food are gigantic. Ironically, your safest bet would be the value menus at large fast food chains, as their profit margins don't allow for as much overage and they have well-defined "idiot proof" food assembly lines.
  • cece5300
    cece5300 Posts: 48
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    Personally I don't care, and I'm not going to drive myself crazy worrying about it. I've lost all my weight I wanted to lose and then some. The MFP calories are an estimate, nutritional labels are an estimate, exercise calories are an estimate. You're never going to truly know, but I've successfully lost weight with exercise and regulating food. I weigh meat but that's about it. I'm not going to make myself obsessed.