An Updated Definition of “Healthy” Foods in the United States: How Do They Measure in Nutrient Density, Cost, and Frequency of Consumption?

Summary

This 2025 study evaluated the real-world implications of the FDA's 2024 update to the 'healthy' food label definition by analysing a nationally-representative food database for nutrient density, cost, and consumption patterns. Whilst qualifying foods were generally more nutrient dense than non-qualifying alternatives, important paradoxes emerged: qualifying plant proteins (predominantly nuts and seeds) were paradoxically less nutrient dense and significantly more expensive than non-qualifying plant proteins, and qualifying mixed dishes were also more costly. The findings suggest that widespread industry reformulation to reduce sodium, sugar and saturated fat may be necessary to improve the market availability and affordability of FDA-compliant 'healthy' labelled foods.

UK applicability

The findings may have limited direct applicability to UK policy, as the UK's nutrient profiling and front-of-pack labelling systems (including FSA Nutrient Profiling Model and voluntary traffic-light labelling) differ substantively from the FDA framework. However, the core observation—that nutrient-density criteria can inadvertently disadvantage affordable plant-based proteins and combination foods—may inform UK food policy discussions around accessibility and dietary equity.

Key measures

Nutrient profile scores (Nutrient Rich Foods Index 9.3 model), monetary cost per unit (based on national food prices), weighted frequency of consumption (Food and Nutrient Database for Dietary Studies)

Outcomes reported

The study compared foods qualifying under the 2024 FDA 'healthy' definition to non-qualifying foods across nutrient density (Nutrient Rich Foods Index 9.3), monetary cost, and frequency of consumption using nationally-representative food and dietary data. Overall, qualifying foods demonstrated significantly higher nutrient density than non-qualifying items, though cost and consumption patterns varied substantially by food group.

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