Guest post by Lisa Richardson MS, RD, LDN
Pretty much everyone agrees that nutrition is confusing! One reason that it feels so confusing is the way that food marketing sells by highlighting nutritional science. Although the US FDA regulates nutrition claims, they remain prone to misinterpretation.
Understanding nutrition claims is a key trait of a nutrition savvy feeding therapist. Feeding therapists are important educators and trusted sources of information for families. Tactful, gentle correction of nutrition inaccuracies and myths can reduce family stress and anxieties.
In this blog post, I’ll break down food marketing speak and help you recognize one type of commonly used marketing claim, the structure function claim.
(This post is adapted from an article on my website that is a specific to nutrition claims for infant formula.)
What are structure function claims for food?
Structure function claims are statements that describe in plain language the relationship between a nutrient or ingredient and the normal structure or function of the human body. For example, there is a well-known nutrition claim:
At first blush, it seems straightforward, however, the words used to describe the relationship are imprecise from a scientific standpoint. Nutrients work through cellular reactions, which are complex processes. Cellular processes then influence body systems. Body systems are groups of organs and tissues that word together, such as like nervous, immune, and respiratory systems).
An excellent example of the complexity is vitamin C, a nutrient that has multiple biological roles in cells. Some of these cellular roles can be grouped together through their influence on immune system functioning.
Therefore, this function claim is true:
But this relationship is not unique! Vitamins A, B12, D, thiamine, riboflavin, and niacin all play roles in the immune system. The minerals zinc and selenium are important as well.
Structure function claims are about general well-being, not diseases.
Structure Function Claims Regulations
Structure function claims are not pre-approved by the US FDA, but they are regulated. For conventional foods, the FDA doesn’t even require companies to notify the FDA about their use. However claims must be truthful and not misleading, though companies can stretch the truth with sly copy writing.
The FDA must be notified about structure function claims for dietary supplements (vitamins, minerals, herbs, enzymes, and many other ingredients). Also, these products must include a disclaimer that the FDA has not evaluated the structure function claim. The disclaimer is usually written at the bottom of the label or website.
What are health claims?
Health claims and structure function claims are easily misconstrued.
Health claims are statements that show a food (or a component of a food) may reduce the risk of a disease or a health-related condition. These authoritative statements must be supported by scientific evidence. Health claims must be approved by the FDA before they appear on food labels.
Since scientific agreement varies the FDA designates two types of health claims:
- Qualified health claims have some evidence, but the evidence is not powerful enough for significant agreement among qualified experts. Examples of qualified.
- Authorized health claims do have significant agreement among experts. The
What is the difference between a health claim and a structure function claim? (h2)
Structure function claims are about normal body functions. On the other hand, health claims focus on disease reduction or prevention.
Earlier, I gave the example of a structure function claim about the mineral calcium, “calcium builds strong bones.” One of the 12 FDA authorized health claims concerns calcium:
“Adequate calcium and vitamin D throughout life, as part of a well-balanced diet, may reduce the risk of osteoporosis.”
You’ll immediately notice that health claims are longer statements than structure function claims. They also provide important contextual information about the relationship. In this example, time span is highlighted (throughout life) and the synergy with vitamin D.
Structure Function Claims Are Summary Statements (h2)
Structure/function claims are mental short-cuts that loosely describe a relationship of a food to the body. They are summaries, handy but imprecise, more like an impressionist painting than a photograph.
Structure/function claims simplify something that incredibly complex. Certainly, making a concept easier to understand has advantages. The downside is that their imprecision (lack of exactness) leaves them open to exaggeration and logical errors.
Structure Function Claims Are Easily Misunderstood
Nutritional science is confusing to many people and structure function claims are a big reason why. These claims come up not only in marketing, but also in news reports of the latest research.
Structure function claims are logically because context is missing. Context is essential for understanding nutritional science. Without a backdrop, assumptions are easy to make. Indeed, context is what trips most people up when trying to understand the latest nutrition headline or article.
Take for example, this structure function claim example “Carrots help you see” Many parents have used that one (along with “spinach will make you strong”) to entice children to eat their vegetables.
Let’s unpack this relationship and examine the context. We’ll also look at how simplifying a message can lead to false assumptions.
A Structure Function Claim Example (h3)
Carrots contain vitamin A, which is indeed important for normal vision. Vitamin A deficiency can cause vision problems, including night blindness or in its most severe form, irreversible blindness.
The relationship between vitamin A and vision is limited to a state of deficiency. The relationship ends when one eats enough vitamin A. While tempting, one cannot extend the relationship further.
Plus, many foods contain vitamin A! Carrots certainly are a convenient and tasty package for them, but it is not an exclusive one. There is a relationship, but it isn’t necessarily a strong one.
Nutrition claims are often logically challenging! Young children with undeveloped logic skills will sometimes think the reverse is also true – that eating more carrots can make one’s vision even better than it is. But this simply isn’t true. It is a logical error easy to make. Indeed, the Allied Forces tried to fool the Nazis with this myth in World War II!
How can formula nutrition claims mislead?
Formula nutrition claims can mislead parents by leaving out important context. Just as a magician’s sleight of hand distracts you from what they are really doing, marketers artfully use nutrition claims for persuasion.
Often a stronger relationship is implied than can be supported by science. The relationship is technically true, a company is violating any US labeling regulations. It is not actually misleading, only potentially misleading. Moreover, the First Amendment protects commercial speech.
As I explain in my article specific to structure function claims for infant formula, marketers present the public with a set of complex set of “one-to-many relationships”. One ingredient is linked to many nutritional or biological functions, which is certainly accurate as shown in the example about vitamin C.
The reverse is also presented, a single body function that is influenced by more than one ingredient. This relationship is also true!
The recent trend in promoting “gut health” is an excellent example of this relationship. Consider all the different foods and ingredients you’ve heard about using this structure function claim. You’ve likely seen it advertising cereals, protein bars, crackers, and smoothies, to name just a few.
To sum things up:
- Nutrition savvy feeding therapists can help parents reach their feeding goals through education and tactful correction of nutrition myths.
- Food marketers used nutrition-related claims about food frequently. The way they use claims can sow confusion.
- Structure function claims are statements that describe in plain language the relationship between a nutrient or ingredient and the normal structure or function of the human body. These types of claims are about general well-being. These claims are not approved by the FDA.
- Health claims connect foods to disease prevention or risk-reduction. These claims must be approved by the FDA. There are two types of health claims, qualified and authorized.
- If you ever need to explain the concept of a structure function claim to a parent, the example of carrots and eyesight is a useful example.
If you have questions about a nutrition claim, comment on this post!
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