Digging up the dirt on "clean" dietary labels: Public health considerations and opportunities for increased Federal oversight.

Abstract

"Clean" dietary labels are often viewed by consumers as referencing products that are minimally processed, without additives, preservatives, artificial colors, or ingredients, but may also be interpreted as vegan, gluten-free, dairy-free, "real," or "natural." Although the "clean" diet trend continues to grow in popularity, there is a lack of consensus regarding the definition and use of this terminology with a corresponding lack of regulation for such labels in the United States. This multidisciplinary scoping review examines the public health implications of the "clean" label trend and the legal and policy landscape for regulation. We report on findings from case law and legal research generated through the Westlaw database and from the U.S. Food and Drug Administration (FDA) enforcement actions and website documents to discuss options for federal- and state-level intervention to mitigate harm. One feasible avenue for change is for the FDA to provide industry guidance, disseminate public statements to debunk myths, and enforce labeling statutes to police deceptive "clean" labeling claims. We also suggest consumer-protection litigation and state-level litigation via attorneys general as alternative actions to combat the abundant misinformation associated with "clean" diets and labels. Although the FDA has taken some enforcement actions, these efforts are insufficient given the proliferation of "clean" label products in the marketplace and the potential for adverse impacts on public health including increased risk for disordered eating. The current unregulated, undefined landscape for "clean" dietary labels thus requires urgent action by federal authorities and state attorneys general.