Along with the other labeling changes, the FDA has issued a final rule to update and establish Reference Amounts Customarily Consumed (RACC) to better reflect what people actually eat. As a result, food manufacturers may be required to update their labels and serving sizes based on the new reference amounts. In addition, this could potentially have an impact on your products’ Nutrient Content Claims.
In general, the RACCs have been updated to more accurately reflect the serving sizes Americans actually eat at one sitting. For example, the RACC for soda has increased from 8 fl oz to 12 fl oz, which makes sense given that most cans of soda contain 12 oz.
Serving sizes are determined by the RACC as a result, manufacturers may need to adjust the serving sizes of their packaged foods. Additionally, for certain products that are larger than a single serving but that could be consumed in one sitting or multiple sittings (e.g. a bag of chips, can of soup, pint of ice cream), a “dual column” label will need to be provided for per serving and servings per package.
(For example, both a 12 fl oz and 20 fl oz bottle of soda should be labeled as 1 serving.)
(For example, a 24 fl oz bottle of soda would require a dual column label – one column for the nutrient amounts per 12 fl oz and one column for the amounts per 24 fl oz – because it is 200% of the RACC of 12 fl oz)
Changes in the RACC may impact the eligibility of certain Nutrient Content Claims and Health Claims. Be sure to evaluate your entire package when updating labels with RACC changes.
Example: Excellent Source of Calcium vs. Good Source of Calcium
The RACC for yogurt has gone from 225g to 170g. Additionally, the %DV for Calcium has increased from 1000 mg to 1300 mg.
With the original serving size of 225g, the %DV for Calcium (in this example) was 25%, resulting in eligibility for an “Excellent Source of Calcium” claim.
However, the amount of Calcium in 170g of the same yogurt results in a %DV of 15%, which is considered a “Good Source of Calcium”.
So, manufacturers are going to have to be extra careful with the Nutrient Content Claims with regard to the new RACCs.