HomeMy WebLinkAboutItem 12b - Front-of-Package Labeling
DATE: May 2, 2023
TO: Honorable Mayor and City Council
FROM: Dominic Lazzaretto, City Manager
By: Justine Bruno, Deputy City Manager
SUBJECT: REPORT, DISCUSSION, AND DIRECTION REGARDING FRONT-OF-
PACKAGE LABELING FOR FOOD PRODUCTS
CEQA: Not a Project
Recommendation: Provide Direction
SUMMARY
At the regular City Council meeting on March 21, 2023, Mayor Pro Tem Verlato
received support to place the topic of front-of-package food labeling on a future City
Council Agenda. This agenda item brings forward the topic of front-of-package labeling
and potential options for the City Council to consider in support of this initiative. At the
conclusion of the discussion, it is recommended that the City Council provide direction
regarding any desired action related to front-of-package food labeling.
BACKGROUND
The desire to inform and protect consumers has been a priority of the government for
many decades. Labels bearing information that identify the product, the net quantity,
and associated manufacturer have been required in the U.S. since 1967, under the Fair
Packaging and Labeling Act. Since then, more federal legislation has been enacted to
further inform consumers about their purchases.
The 1990 Nutrition Labeling and Education Act (“NLEA”) marked the first-time food
packages were required to contain standardized information as in the number of
calories, serving size, amount of fats, carbohydrates, sugars, sodium, etc., on the
product. These efforts are designed to encourage consumers to make healthier choices
through the display of nutritional labels. Any additional food labeling beyond what was
required through the NLEA in 1990 is entirely voluntary, as in the case of ‘Facts up
Front’. This initiative has been in place for more than a decade and aims to relocate and
simplify nutritional information for packaged food products. This effort was led by the
Consumer Brands Association and the Food Marketing Institute and seeks to make
Report, Discussion, and Direction – Front of Label Packaging
May 2, 2023
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product comparisons and healthy choices easier for consumers. An example of this in
practice is the calories listed on the front of a can of soda in large font.
Along those lines and expanding on the concept, the initiative to implement front-of-
package labeling has been gaining
momentum recently. In 2022, the
Biden-Harris Administration declared
its interest in pursuing a
standardized, front-of-package food
labeling system. This declaration was
accompanied by numerous petitions
sent to the Food and Drug
Administration (“FDA”) from the
Center for Science in the Public
Interest; the Association of SNAP
Nutrition Education Administrators;
and the Association of State Public
Health Nutritionists, all advocating for
front-of-packaging food labels.
Over the years, various members of Congress have sponsored legislation that would
direct the FDA to develop a standardized front-of-package labeling system, including
warning systems for certain foods. Most recently, this effort took shape as the Food
Labeling Modernization Act of 2021, which was referred to the House Subcommittee on
Health and has yet to move forward. Previous attempts for this legislation failed in 2015
and 2018.
Earlier this year, the FDA announced a new research project that will study effective
methods to communicate nutritional information to consumers through front-of-package
food labeling. This study was noticed on January 23, 2023, and will explore what type of
information and imagery helps consumers better understand nutrition to facilitate
healthy food choices.
DISCUSSION
A variety of options exist for the City Council to support front-of-package food labeling.
Each option has its affiliated costs, timing, and risks, which have been outlined below:
Federal or State Advocacy
The City Council could decide to lobby state and/or federal representatives for
mandatory front-of-package labeling. These advocacy efforts could occur through
written and verbal communications. Although Congressional efforts to legislate front-of-
package food labels have been unsuccessful to date, showing support may have
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May 2, 2023
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positive results. The City Council could also lobby State officials to take action in
California.
Resolution of Support
The City Council regularly uses Resolutions to express their position on an initiative or
policy item or to direct administrative action. The City Council could offer a resolution of
support for front-of-package labeling, requesting this matter be addressed at the federal
level by the FDA or through Executive Action. Passing a resolution of support allows the
City Council to take a position on this topic and express sentiments of support without
investing substantial resources or duplicating any federal efforts that may be underway.
This option could also be taken in conjunction with lobbying efforts.
Local Ordinance Requiring Front-of-Package Labeling
A local ordinance could be developed to require Arcadia retailers to add front-of-
package labeling to food products; however, the creation and enforcement of this
labeling ordinance would involve budget implications and legal concerns. Some of these
concerns include potential legal challenges to the proposed labeling requirements, the
difficulty of enforcement, and the ability of local businesses to implement the
requirements, since most packaged goods are developed outside City limits. In addition,
there would be the threat of federal or state preemptions for any ordinance the City
Council approves. Overall, implementing a local ordinance to require front-of-package
labeling is within the Council’s purview; however, it is not recommended due to the
anticipated costs and potential legal implications.
Other
There may be other options the City Council wants to pursue in addition to what was
proposed above. If there are other considerations the City Council would like to pursue
in support of front-of-package labeling, staff will receive that direction accordingly.
Finally, an option is to take no action on this item and simply take a wait-and-see
approach to this issue.
ENVIRONMENTAL ANALYSIS
No City Council decision is being made as part of this item, thus it is not considered a
project under the California Environmental Quality Act (“CEQA”). Any future decision on
City Council action related to front-of-packaging food labels will return to the City
Council with an accompanying environmental analysis.
FISCAL IMPACT
All the proposed options have an affiliated fiscal impact that range from de minimis
resource use and costs (i.e. advocacy and resolution of support) to more intensive
resource use and costs (i.e. local ordinance creation). Depending on the proposed
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May 2, 2023
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options City Council seeks to pursue, more information can be shared about any
potential fiscal impacts.
RECOMMENDATION
Based on the information and options presented in the staff report, it is recommended
that City Council provide direction concerning the desired action to support front-of-
package food labeling in Arcadia.