compounds in foods and their total contribution to the diet would need to be factored into FDA efforts to determine safe use. Considerable data gathering will be required to incorporate these compounds into the process.

Nutrition labeling of foods as an activity overseen by FDA began in the 1970s and was initiated, in part, due to concern about nutrient deficiencies. It was a voluntary program unless the food contained any added vitamins, minerals, or protein or a nutritional claim had been made for the food, in which case the food had to display a nutrition label. A nutrition label gave information on calories, protein, carbohydrates, fat, and some vitamins and minerals (Lecos, 1986). Information about sodium was not required in such cases unless a claim was made about sodium content. In 1981, in response to the increasing national concern about sodium intake and elevated blood pressure, FDA began to urge the food industry to voluntarily identify the sodium content of foods on the label. In 1984, FDA issued a sodium labeling regulation (HHS/FDA, 1984), which went into effect in 1986, requiring that sodium content be included on any food that bears a nutrition label. The rule also included definitions for the label claims “sodium free,” “very low sodium,” “low sodium,” and “reduced sodium” and described appropriate use of the terms “without added salt,” “unsalted,” and “no added salt” on food labels (HHS/FDA, 1984, 1985).

By the end of the 1980s, new scientific findings about diet and health were increasingly reported, and consumer interest in diet as a way to improve health was increasing. Food manufacturers were eager to market food products to take advantage of this interest. As a result, the marketplace became crowded with claims about the benefits of foods, and consumers and manufacturers expressed concern about the credibility of the food label and its potential to confuse consumers (Taylor and Wilkening, 2008a). Primarily as a result of these events, the NLEA was passed by Congress in 1990,¹⁶ amending the existing 1938 Federal Food, Drug, and Cosmetic Act.

The NLEA was a broad effort not only to reduce consumer confusion, but also to provide information that consumers needed and wanted, by requiring that nutrition labeling rules be put in place by FDA. It further stipulated that declarations of the amounts of certain nutrients would be made mandatory on labels of packaged foods. It required that the government create a framework that allowed manufacturers voluntarily to use