The History of the Nutrition Facts Label

Kelly Therese Pollock  0:00  
This is Unsung History, the podcast where we discuss people and events in American history that haven't always received a lot of attention. I'm your host, Kelly Therese Pollock. I'll start each episode with a brief introduction to the topic, and then talk to someone who knows a lot more than I do. Be sure to subscribe to Unsung History on your favorite podcasting app, so you never miss an episode. And please, tell your friends, family, neighbors, colleagues, maybe even strangers, to listen too. When you walk into a grocery store in the United States, and pick up a package of say, cereal, you expect to find a white box on the back of the package with information printed in Helvetica Black, about the food's macronutrients, things like fat and protein, and micronutrients, vitamins and minerals. The Nutrition Facts Label is so ubiquitous, that you might not even notice it. But how did it get there? Why does it look the way it does? Who decided which things to include? The history of that label is our story this week. In 1904, American author and activist, Upton Sinclair, went undercover in the Chicago stockyards, working in meatpacking plants for seven weeks before publishing the resulting novel, "The Jungle," in serial form in the socialist newspaper, "Appeal to Reason" in 1905. Sinclair's goal was to promote socialism by showing the terrible living and working conditions of those in the meatpacking industry. Publication of "The Jungle," indeed created public outrage, but not in exactly the way Sinclair had intended. Rather, people were appalled to learn about the unsanitary conditions in the packaged food industry, and demanded change. One result of that outcry was the passage of the Pure Food and Drug Act, which outlawed, "the manufacture, sale, or transportation of adulterated or misbranded or poisonous or deleterious foods, drugs or medicines, and liquors." Members of Congress had been trying for some time to pass similar legislation to no avail. But finally, on June 29, 1906, the United States House of Representatives overwhelmingly passed the bill that had originated in the Senate, and President Theodore Roosevelt signed it into law the next day. At the same time, Congress passed the Meat Inspection Act. The regulatory body that enforced the Pure Food and Drug Act was the Bureau of Chemistry within the Department of Agriculture. In July, 1927, the bureau changed focus and was renamed the Food, Drug, and Insecticide Administration. It was renamed again in July, 1930, to its current form, the Food and Drug Administration, or FDA. In the 1930s, the FDA pushed Congress to strengthen existing law, creating an exhibit in 1933 that a journalist dubbed "The American Chamber of Horrors," that demonstrated packaging fraud and economic adulteration, common in packaged food and still legal under the 1906 law. Congress, however, failed to act until tragedy struck, when over 100 people in 15 states, many of them children, died in 1937 when they took elixir sulfanilamide, a newly formulated liquid form of the drug dissolved in diethylene glycol, which had not been tested for safety.

In 1938, Congress passed the Federal Food, Drug and Cosmetic Act, which gave authority to the FDA to ensure the safety of food, drugs and cosmetics. One of the regulatory areas in which the FDA was now empowered to act was in defining and establishing quality standards for food. The first foods to be standardized by the FDA in the July, 1939 issue of the Federal Register, were canned tomatoes, tomato puree, and tomato paste. The resulting standards were essentially recipes of the acceptable ingredients and formulations for a product to be labeled as such. In 1941, during World War II, the National Research Council Food and Nutrition Board first established the Recommended Dietary Allowance or RDA, standards of different nutrients that could guide nutritional intake. The guidelines were then regularly updated every five to 10 years. In 1969, the Nixon administration hosted the White House Conference on Food, Nutrition and Health. In the opening remarks, President Richard Nixon pledged, "to put an end to hunger in America for all time."  Although the conference did not end hunger in the US, recommendations from the conference did change the focus of the FDA, from setting food standards to informing consumers about the food they were buying. In 1973, the FDA published regulations about food labeling, introducing a voluntary nutrition panel for packaged foods. Food producers who wanted to make certain nutritional claims about their foods, for instance, saying that the food was low in fat or high in protein, had to include the panel showing the full nutrition information, including the number of calories, the grams of protein, carbohydrate and fat, and the percent of the US recommended daily allowance, USRDA, of protein, vitamins A and C, thiamin, riboflavin, niacin, calcium and iron. Other values, such as sodium and fatty acids could also be included. Dr. Charles C. Edwards, the Commissioner of Food and Drugs in 1973, explained, "We're not trying to tell the American public what to eat. They can eat anything they want, but those interested can now have specific information about the contents of the foods they buy." Two decades later, this voluntary labeling became mandatory. On November 8, 1990, President George HW Bush signed "The Nutrition Labeling and Education Act" into law, which required nearly all packaged foods in the United States to include, by May 8,1993, a standardized nutrition facts panel, including serving sizes, and the amount of calories, fat, cholesterol, sodium, carbohydrates and protein, as well as select vitamins and minerals. Trans fats were added to the panel on January 1, 2006. In spring, 2016, the FDA, which is now part of the Department of Health and Human Services, announced changes to the design of the label, including standardization in serving sizes, increasing the font size for calories, and updating daily values for sodium, dietary fiber, and vitamin D, with the goal of helping consumers make better informed decisions about their food purchases. Joining me now to discuss the history of food labeling in the United States is Dr. Xaq Frohlich, Associate Professor of History of Technology in the Department of History at Auburn University, and author of, "From Label to Table: Regulating Food in America in the Information Age."

Hi, Xaq. Thanks so much for joining me today.

Dr Xaq Frohlich  10:38  
My pleasure to be here.

Kelly Therese Pollock  10:39  
So I am super interested to hear how you first became interested in this topic and this idea of doing what you refer to as like a biography of the food label.

Dr Xaq Frohlich  10:51  
I got into this topic, I was in graduate school, and I had friends visiting me from Europe. And at that time, food labeling was very different in the United States and in Europe. Now you, you actually can find their version of a nutrition facts label. But one of my friends visiting from Europe, looked at a package, saw the nutrition facts panel, and said, "That's so American." And I knew what she meant. She kind of meant two things by that. One was she thought it was very scientistic. Like, Europeans know what good food is, they know what to eat, they have a sort of idea of what they should eat. And they think of Americans as being sort of diet crazed people who are always chasing science. But also there is this kind of sense that it's legalistic too, in the sense that we have these warning labels on everything. And Europeans love to laugh about our sort of litigious culture where, you know, it's like, you have a label on a banana saying, "Be careful, don't slip on it." So I think that reaction was, what made them made this comment about the label. And that got me interested and thinking, "Where does this label come from?" And so I did a paper on that, but in the process, realized the Nutrition Facts Label appeared in the 1990s. But there's a much older story, and it plays a much bigger role than just nutrition and information. And so this that became the fuller project was trying to figure out that longer story.

Kelly Therese Pollock  12:14  
Yeah, I mean, it seems now it's so ubiquitous, you almost forget that there wouldn't need to be a nutrition facts label at all, you know, it just sort of is part of what we expect now. So could you talk a little bit about the how you did this history, the sources, you were looking at the way you were uncovering this, this longer history, really for the past century or so?

Dr Xaq Frohlich  12:36  
Yeah, so initially, it started by looking at the materials that you would find through the Food and Drug Administration. They have a Dockets Management Office, which handles the more recent cases and issues that they deal with. And then they have the archives in the National Archives. But actually, I had a bit of luck, in that I took a class with a guest lecturer at Harvard in food law, and he actually works in a big food firm. This is Peter Barton Hutt. And his firm represents a lot of big, familiar household brand name companies, including food companies, and he himself is a sort of very important food lawyer, and I met with him outside of the class and told him about what I was working on. And he said, "Oh, yeah, I'm the reason why there's a nutrition label." And I was like, "Why is this?" And he said, "Well, I was at the FDA in the 1970s, when we introduced that." And he then invited me to go look at the Covington and Burling is his law firm, their archives, which he was very instrumental in developing. So when they have clients or cases, they keep all of their materials related to a subject. And so they have very extensive materials. So a big part of the early research came out of going through those materials. However, then I looked at a lot of other archives related to medical scientists who were active in policy at scientific associations that the FDA turned to, and that was good because his claim that he was the reason why there was nutrition labeling was a little over simplistic and self serving. There was already a lot of interest in nutritional labeling. One good example of this was that Esther Peterson is a well known to people who do history of consumer activism. She was actually very involved in the 1970s with giant food supermarkets and introducing a nutrition label before the FDA does. So I started comparing the story that the archives and this law firm has with archival materials I find with other people who are very involved, as well.

Kelly Therese Pollock  14:41  
So one of the stories you tell in this book is not just the story of the label or what the FDA is doing, but who the FDA and more generally, you know, the government considers to be the consumer. So could you talk a little bit about that, how how they're thinking, how everybody's thinking about who the consumer of food is, shifts over time?

Dr Xaq Frohlich  15:06  
Yes, the idea that the FDA's sort of core mission, one of them is consumer protection. And so one of the things I talk about in the book is how, who they imagined to the consumer is changing. And that explains the change in their policies. In the early years in my book, which is in the 1930s, and 40s, they imagined the consumer to be a healthy person who's sort of, they have what's called an ordinary consumer standard, where they're imagining the consumer to be this ordinary person. And we need to create food policies that would be simple and easy for that ordinary consumer. They're also worried about consumers of drugs, which are very different. And so one of the big concerns they have is between keeping food products separate from drug products, because the consumers of drugs are patients that have special needs, they're talking with their doctors. So initially, there they have this ordinary consumer in mind. And one of things I talk about is that, you know, many of many, many historians of consumers will point out that this was often imagined to be the sort of middle class white housewife as kind of the person that would imagine for a lot of food consumers. By the 1960s, that's changing, you're getting companies interested in other niche consumers. But in the background, that's who they're imagining the ordinary consumer to be. One of the things that changes in the 1960s and 1970s, they're recognizing that a lot of consumers are seeking more information than just what is this food. They want to know information about its health properties, how it was made, how to use it. And so then in the 70s, I argue that they start working with what I call the informed consumer, this idea that a person is literate, they're seeking out information, we need to give them labeling information. And so there are kind of cycles in who they're they're targeting and who they're thinking about. In later years, I talked about other types of consumers that they're imagining, ones who are not, or have many different interests, and they're doing in one mode, they may be interested in, what they're feeding their food, but in another moment, they might be interested in environmental concerns. And so the label becomes this kind of complicated mosaic of lots of different things that a consumer might seek. There's also in the background, a concern among industry, as well as policymakers about how rational the consumer is, Are they someone who are who's motivated by rational interest and the kind of functional qualities of food? Or are they motivated by sort of hidden irrational desires and or rationally irrational behaviors and these kinds of models of consumer?

Kelly Therese Pollock  17:46  
the FDA is kind of the main government player in this story that you're telling. But they're, of course, not the only government agency that interacts with food in various ways. So could you talk a little bit about that interplay, and at certain points, the FDA is almost at odds with other government entities and how that plays out over time?

Dr Xaq Frohlich  18:09  
Yeah, the FDA is the sort of main government character in my story, and I don't talk about other important characters as much as I could. The kind of other big food character in the federal government is the US Department of Agriculture. And the USDA and FDA are very different entities. First of all, the US Department of Agriculture is much bigger than the FDA in terms of size, and people. Originally, the FDA actually was in the US Department of Agriculture, and it separates out in the 1940s. The US Department of Agriculture's mission is to promote agriculture and promote food production. And so there are times where it's clearly supporting a lot of trade industries, whose interest runs against a lot of public health concerns. In the 1950s and 60s, you get the rise of what some people call negative nutrition, the idea that we're eating too much food, and the health message should be you should eat less. That runs against a lot of the food promotion activities of the USDA. And so those are moments where as the FDA adopts that new idea that low fat labeling might be appropriate, and other kinds of arguments like that, that affect the food industry, they start to butt heads with the USDA.

Kelly Therese Pollock  19:26  
So then, of course, the FDA is also has a lot of interplay with with industry. So there are various forces in industry who maybe want more labeling in certain ways. They want to be able to make claims on packaging, or they want less labeling, they don't want to have to disclose certain things that are going on. Can you talk about the FDA relationship with industry writ large, over this time period that we're looking at? And it seems like we got to a place toward the end where industry is pretty happy with the way things fall out.

Dr Xaq Frohlich  20:00  
In this book, I will say the book is very much focused on FDA activities. But one thing I think that makes it different than a lot of other books about the FDA is that you don't always have the feeling that the FDA is driving the story. In fact, I think a lot of histories that look up the FDA tell a very top down narrative where the FDA is setting policies and, and problem solving an issue and framing it. And in my story, there are moments where you're kind of asking the question, "What is the FDA doing?" because it's other people who are really pushing that. A big one is industry. And one way that the industry really shapes FDA policies on food labeling, is through advertising. Advertising is legally connected to labeling. But often the food industry can push advertisements out that really push the boundaries of what's allowed and what's not allowed, and then wait to see how the FDA responds. And this is a way that they start shifting the line about what is appropriate. This is really a big part of the story in the 1960s with diet foods, in particular via vitamin food, vitamin supplements, artificially sweetened foods, low calorie foods, and low fat foods. They play with advertisements that aren't clear about who they're really trying to target in a way that circumvents a lot of the FDA's policies. This is also a lot of stories where other groups, consumer advocates play an important role as well. So anyway, I like to think of the book as being different than a lot of FDA histories, because you're seeing a lot of outside forces working on the FDA.

Kelly Therese Pollock  21:33  
Yeah, I want to pick up on the consumer advocacy groups and things like that. So my other podcasting life, I'm interested in political activism and the types of activism that can be most effective. Could you talk a little bit about some of these activist groups, and they the methods that they're using to try to influence what the FDA is going to mandate or ban or allow, and you know, what, what that activism looks like?

Dr Xaq Frohlich  22:01  
In the early years, and that I explore in the book, before you start getting into information labels, the FDA's focus was on creating food standards. And you have a lot of home economists who are very active, who are advocating in favor of FDA food standards, in part because they see them as a tool the FDA can use to ensure that food is what consumers expect it to be. There's a lot of anxiety about new additives, about fabricated or manufactured foods that the consumer might not know how it was made, or recognize the ingredients in it. So you have people like Jessie Coles, who's a home economist, who publishes a bunch of books in favor of food standards. She describes the FDA Food Standards system as being about simplification, you're trying to simplify the amount of products out there, so the buyer is not overwhelmed with this, and she argues is even advantageous to big national brand companies because it means that they can focus on branding, focused around sort of key attributes instead of just too many choices that overwhelm consumers. You have other consumer activists, there's Ruth Desmond, who creates the Federation of Homemakers. She sort of sells herself as a housewife who's now active. And she takes advantage of the open nature of the FDA's food standard systems, they hold public hearings. And so she attends those, she gets to testify in them. And she's clearly a very colorful person in terms of like speaking in a way that gets gets quoted and, and such. During the peanut butter standard hearings, where they're debating what percentage of the peanut butter should be peanuts. She argues that like if it's too low, it might as well be called cold cream. And so this gets a lot of publicity. In the 1970s, when the FDA shifts to informative labeling, it gets rid of that public standards hearing system and instead asked for its solicits comments that it then reviews and publishes in the Federal Register. So this is a big change in its procedures. And it also changes the kind of activism that you see how people engage. Probably the biggest change in activism in my story is that in the, in the sort of 1930s and 1960s, a lot of the consumer activism shaped around the housewife. And you have great examples of this. My favorite example are the codebreakers. It's a group of housewives who are unhappy with what's called closed date labeling. They know that manufacturers are telling retailers when food goes off, or when it should be cycled out. And they break the code that the manufacturers are using for this retailing and then they start publishing booklets so that housewives will know how to go in and and buy the food and they effectively they make it like open date labeling. And so this leads supermarkets to shift to open labeling. Over the course of the 1970s, housewives become less important as activists and you start to get a different kind of activism. You have the rise of the Center for Science in the Public Interest CSPI, with Michael Jacobson. A lot of them are much more focused on health, nutrition. They're more scientific in how they frame their arguments about activism. And so that shift from kind of the idea of the housewife being an important political sort of character to center our activism around to it being more about your health, and your nutrition is a big change.

Kelly Therese Pollock  25:42  
I want to move toward the 1990s food labeling. And I think it seems counterintuitive at first to think that we're moving through an era where everyone's saying we need less government, we need smaller government moving out of sort of the New Deal era. And that leads to in fact, mandated nutrition facts on every food product. So can you talk a little bit about that interplay and how it's, it's actually consistent with the idea of smaller government, whatever that means, and you know, how how we get by in doing this mandatory food labeling?

Dr Xaq Frohlich  26:20  
The book is a history of food label, and sort of shows this increasing expansion of the food label as a place where you're trying to deal with a wide variety of political issues. But one thing I'm always careful to point out is I don't tell a liberation narrative, it's not like, more and more information appearing on the label is leading to consumers being more empowered. And in a way that's really important to understanding the nutrition label. You have a policy where people are concerned about public health, they're concerned about the ingredients. And instead of those concerns, happening with food standards, the FDA decides in the 1970s, "Okay, we're going to let people create non standard products, they're going to meet the needs or interests of their consumer markets." That means now you can make a diet food and you don't have to get a standard for it. You can make the low fat version or the low cal version. But then the compromise, they argue is that we'll put it on the label and let the consumer decide. And in the 1970s, before we get to the 1980s, and the 1970s. This is happening in an era of very low public support for government. So the fact that the FDA basically invents a new rule, and invents new laws about how it's going to do labeling, works, because it's arguing that we're allowing the industry now to innovate in foods create more products, and then they can voluntarily put this nutrition information on there, if they do this, so that consumers can decide for themselves. And that idea that labels allow consumers to decide for themselves is really important to its political success. The FDA is not telling you what's good or bad for you, it's just requiring manufacturers to disclose that information. And then you can decide, and so that moves forward up to the present, this idea that we're enabling people to make their own lifestyle decisions and risk decisions with the information on label. But I one of the things I argue in the book is that this comes at the cost of having the political debates at the federal level or with the Food and Drug Administration about what is desirable in our food system. So a lot of times labeling is the kind of opt out way of handling a political problem. Instead of saying we don't want this kind of food item. We don't want this kind of food. There's a sort of solution, we'll put on the label and let consumers decide.

Kelly Therese Pollock  28:44  
So I want to talk about the the policy decisions that go into what the label looks like what's on it. It seems like such a straightforward after the fact like such a straightforward, like it's just the facts, you just see, you know, what's in the product, and what percentage of daily value and such. But of course, there's all sorts of decisions that go into how this is displayed, what's displayed, what isn't on there. Can you talk a little bit about the ways that the FDA is thinking about this, how they're making decisions about what this actual nutrition facts panel is going to look like?

Dr Xaq Frohlich  29:21  
That question about the label is most interesting, in the chapter, I talked about the nutrition facts label in the 1990s. And it's fun, because you see this thing, you take it for granted that this is what it looks like, and this is what it says, but you're in the 1990s, you're looking at the people deciding how to design this and they're making big decisions that would be surprising to us now. The name "nutrition facts," for example, they have they considered nutrition guide and nutrition values, and then they settled upon facts. And I think this reinforces the idea that this is an objective description of what you're reading. And even though part of it It changes from the early version nutrition label because now they have these percent recommendations on the label. The other thing the FDA is, has national recommended levels for certain nutrients on the label. These are the recommended daily allowances that the National Academy of Sciences has been publishing for decades. So some of the information on the label reflects those. But then it has to come up with and adopt the recommended allowances for things like fats. And it does this by drawing on guidances coming from the US Department of Agriculture. It emits an entirely new thing called DRVs, the daily recommended values, which is a mixture of those two different sources of recommendations. They have debates over how to calibrate the label. It's based on an a recommended diet of 2000 calories. And there are big debates about this. because the average adult male should probably have 2300 calories, the average adult female should probably have more like 1800. And there are debates about whether they want to go lower for men, because they're worried about men having too much food. And eventually they settle on this number 2000, for very pragmatic reasons. They decide that by it being rounded to such an even number, consumers will recognize it's not precise. It will be easier to do math. And they would rather be on the lower side than the higher side because at the time, they're concerned about Americans getting overweight. And so even though it looks scientific, it's very political and pragmatic and bureaucratic, the decision making going into the number of the 2000 calories. And then there are lots of different political interest groups that that raise points that the FDA gets concerned about, minimum font size. AARP writes in saying we're concerned about the elderly who have to read this. And so they put in rules about minimum font size. The kind of funnest thing for me to learn about was when I interviewed Burkey Belser, who just recently passed away, who is the head of the design firm, and the design considerations. One of the things he said was that the FDA commissioner contacted him, David Kessler and said, "We're going to change this label and no one's going to realize it unless we create a really clear design behind it." And so Belser and his firm work on creating this black and white, sort of very simple design style. And he in an interview, he said it's a government brand. And later on to the brand got extended to Drug Facts. And even today, I think the popularity and the iconic aspect of the label has more to do with that design aspect than it does the actual success of it as a functioning health tool. And, and so the kind of design considerations are really interesting as well.

Kelly Therese Pollock  32:54  
I loved the part about design. It's the this panel is just a thing of beauty. And it's so interesting to think about all the ways it could have been different.

Dr Xaq Frohlich  33:04  
And he some of the design graphic versions of it had color, and they decide not to include color. And the reasoning was that it would be more expensive to require manufacturers to include color. But I have to admit, I think it adds to the kind of view of the label as the little objective part of this otherwise very colorful marketing thing of a package. So it adds to this idea of it being a kind of trustworthy, objective label.

Kelly Therese Pollock  33:35  
So I have spent a lot of time looking at labels, looking at the nutrition facts labels, but I suspect a lot of people have not spent a ton of time looking at it. Can you talk about the ways that the reactions of the food industry, the food actually changes as a result of the label, whether or not people are spending any time looking at it?

Dr Xaq Frohlich  33:55  
Yeah, the question I always get asked when I talk about this, this story is, "Does anyone even read the label?" Actually, I usually have one of two reactions. I either have people who are really into the label, I didn't actually read labels before this project. And so I learned a lot from my audiences. Like they'd be like, this is one little label thing and or labeling. What do you think about that for ingredients? And, and over time, I learned a lot about the label from from the audience. But then I asked that a lot of people are like, does anyone even read them? And there are lots of studies that look at how people read them, you know, and do people read them. And a lot of people don't. Also a lot of people spend very little time reading them or they read them at particular moments, like maybe the first time they get a food, they'll read them. Or when some big life change happens. Either there's a medical diagnosis, or they have a kid. They might read them but then they won't read them again. But one of the points I make in the book is that even if you don't read them, they have a direct impact on the food you eat. And this is because every time the FDA changes the labeling policies, the food industry starts formulating its foods. And so there was an FDA historian, Suzanne Junod, who when this was happening in the 1990s, she grabbed a bunch of packages. And then she got packages after the introduction of the nutrition facts labeled, because she wanted to show that there was actually a change in the nutrients and in the ingredients, because they're concerned about if some people are reading them differently, and that affects buyers, then they want to create formulas that make their food attractive. And so. So yeah, one of the arguments I make is that even if you're not reading these labels, the labels are affecting your food.

Kelly Therese Pollock  35:40  
So the nutrition facts panel, of course, is not the only type of labeling on a package. And there are other you talked about other kinds of labels that don't come from the FDA, that different organizations have developed, have let people opt into or opt out of. Could you talk a little bit about that, things like organic labeling and GMO? And how that, you know what, what that looks like?

Dr Xaq Frohlich  36:07  
Yeah, so one of the reasons I talk about other labels is because the nutrition facts label is the example of a kind of informative label where it's supposed to tell you something about something intrinsic in the package. So you know, this food has these nutritional properties. A very different kind of label would be the organic label, where nothing about the word organic says anything specifically to you about what that means. And so it's what economists call credence labels. It's entirely about your belief, and whoever is certifying this word organic. So you would have an idea of what fair trade means, because you have some idea of the organization saying this is a socially just way of paying people for producing our food, or with organic, you would say, you know, this is how you have to produce the food in order for it to be organic. And so I entered that interested me because it's different than the nutrition facts table, where it's that we're saying you now have this information about it. The credence label is entirely about your trust in that certifying organization. And so in the case of organic, the big story there in the 1990s, is you have a lot of regional organic labeling groups. And because of their concerns about the term getting misused by sort of people in the market, they invite the US Department of Agriculture to create the USDA organic label, and legally enforce it. And the USDA is not as invested in organic as many of these regional people. And so there's a kind of watering down a lowest common denominator approach they have. But it does keep out certain things they're concerned about in terms of pesticides, in terms of genetically modified foods. But it's very much a story about mainstreaming this, this sort of alternative food movement. Other kinds of labels, though, you have a lot of concerns about risk labels. I think in a way, the ingredients panel also gets used this way, where people who are really concerned about one particular ingredient, and they feel like it's unhealthy or dangerous, they'll turn to the ingredients panel and try to like, look at that. And if they see it, they'll be like, I'm not going to have this. So they might be concerned about, you know, red dye 40, or a particular kind of artificial sweetener. So one of the things I talk about are these different kinds of uses of the label. The other thing that was important to me, there is again, challenging this idea that the simple story that more information means more informed. You also have the case of certain labels, where it's pretty clear the intention is to make the consumer sort of understand even less of what's happening. And this is I think, clearest with the example of the GMO food labeling, kind of compromise. In 2016, Congress passes this law that basically says, "Okay, we're gonna have GMO food labeling," but the way it's interpreted there's sort of two things the industry and government do to kind of undermine this, is it really informing the consumers? First, the US Department of Agriculture decides that they want to call these bioengineered foods. No one is calling these bioengineered foods in the public. And so I think that was very much a way of saying, "Okay, we're not going to use this stigmatized name that has been used before. We're going to use this other." And the other is that that the law allows you to put this label anywhere you want. And this is happening right at the moment where supermarkets and manufacturers are starting to use QR codes, these kinds of box things that you can scan with your cell phone to get information, and many of them bury the GMO label in that digital information. So it's available to the consumer, but you have to kind of actively find it. And so I just made this point that labels can obfuscate. They can they can have you sort of undermine your ability to be informed as well. 

Kelly Therese Pollock  40:01  
So you started by talking about having friends visiting from Europe and how that made you start thinking about this project. You have taught in various different countries. I wonder if you could reflect a little bit on how living in those other cultures has affected your thinking about this?

Dr Xaq Frohlich  40:19  
Great question. I think one of the things that interested in me and my friends comment is this idea about how much of this is an American story, and how much of this is true of living as a modern consumer anywhere. So I think, in Europe, and I lived in South Korea, they are much more accustomed to having the government play an active role in codifying rules about how the market works. So once Europeans did adopt nutrition labeling, I think in a way they did it, they you know, they did it in a more standardized approach. They had much more stricter rules about health claims, the kinds of disease claims and health claims that could be made. And they were much in some ways, they gave industry more options, because they, they hired panels decide which ones are good and which ones are bad. Here in the United States, the FDA has not fully said that. And so it's been kind of a game of what what can be tried? And when will the FDA say no, that's not good. So in other countries, they tend to enforce the rules that they set. Here, there is a kind of cat and mouse approach to governance, where sometimes the rules say one thing, but then if the FDA isn't enforcing it, businesses may play with that and push those boundaries. There's also this idea that Americans are much quicker to buy manufactured foods with particular traits. I think we do actually entertain diet fads much more easily than other countries. We have a less rooted food culture in that sense than you find in Europe and South Korea. That's sort of broadly speaking. There are a lot of other countries are dealing with the same kinds of problems we are, about increasingly processed foods, because we're all overworked. And so we're outsourcing our cooking to industry. And that's not industry's fault, like we people want to cook less. And so we rely on restaurants and pre prepared foods more. And that means that those are the people making decisions about our food, and food labeling as a kind of, in my opinion, a sort of very superficial approach towards trying to solve that. And I think in a way a lot of countries are taking more seriously the idea that they need to directly engaged with food industry about what ingredients are appropriate and which ones are deceptive, or dangerous. I think in the last year, I'm seeing a lot more activity among the Food and Drug Administration. So I don't know what that means in terms of how that will translate to changes in policies.

Kelly Therese Pollock  43:00  
So I have a million more questions I could ask, but people should just go read the book. So how can people get it?

Dr Xaq Frohlich  43:06  
Order online, it's through the University of California Press. So you can find it there. Also, obviously, on Amazon and other kinds of online retailers, and yes, I hope they read it. And I'm excited that it's in the world and that people can learn about this really interesting story.

Kelly Therese Pollock  43:21  
Thank you so much for speaking with me. I really enjoyed learning this story. So much of it is during my lifetime, and I still didn't really know all that stuff that was happening. So thank you so much.

Dr Xaq Frohlich  43:33  
 My pleasure. Thank you. 

Teddy  44:01  
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