What is Nutritional Analysis?
Foods are composed of a complicated matrix of compounds. Among these compounds are nutrients that are essential for life and growth. For human food, these nutrients have been defined and mandated by governments to be disclosed on food packaging in most countries around the world. These mandates are intended to help populations reduce nutrient deficiencies and preventable diseases caused by malnutrition. A nutritional analysis is the description of the method used to determine the amounts of these nutrients in a particular food. Nutrients are generally reported on a one hundred gram basis as a certificate of analysis (Fig 1.1).
After obtaining results, the nutrition analysis is used to prepare label nutrient disclosures on food packaging. In the United States, these disclosures are regulated by the FDA and titled “Nutrition Facts”. Nutrition labeling requirements for Nutrition Facts are contained in 21 C.F.R. § 101.9 and required on most food products offered for sale. 21 U.S.C. § 343(q). The Nutrition Facts contain the amount of each nutrient in a serving of food and are characterized by a percent daily value (%DV) that is based on Daily Reference Values (DRVs in Fig 1.2) and Reference Daily Intakes (RDIs). The %DV helps consumers understand how the amount of a nutrient present in a food fits into their daily nutrition needs. In addition, there are both mandatory nutrients and voluntary nutrients that may appear on Nutrition Facts. Depending on how voluntary nutrients enter food products, and whether or not nutrients appear in other label statements outside of the Nutrition Facts, voluntary nutrients may become mandatory to disclose. This is an important consideration when designing Nutrition Facts for your food label to make sure that there is space on the label artwork to accommodate these additional nutrient disclosures.
In Nutrition Facts, nutrients are declared based on a foods serving size. Serving sizes are regulated by the FDA and determined by a reference amount of food customarily consumed per eating occasion, or RACC table, for different food categories. Choosing the wrong serving size is a common mistake and can be a challenging exercise when food does not fit neatly into any one category. Servings must also be displayed in an appropriate common household measure like a teaspoon, tablespoon, or cups. 21 C.F.R. § 101.12(b). This allows consumers to compare the nutrition values between different options for the same categories of food. It empowers them to make healthy eating choices for themselves and their families.
The FDA is not so much concerned about the method food manufacturers use for nutritional analysis, and database calculations are an acceptable method in most cases. They are more concerned that the resulting Nutrition Facts be truthful and not misleading. Their role in regulating food labeling is more of an enforcement function rather than an approval function. The FDA does not approve food labels or the Nutrition Facts on them. However, they do regulate food labeling and enforce those regulations as resources allow and necessity guides them. If they do decide to make a determination about the truthfulness of the Nutrition Facts on a food label they will obtain samples and send them in for chemical analysis by an accredited laboratory. There is a protocol for this sampling and accepted methods of analysis that are used. This protocol and accepted methods of nutrition analysis are the gold-standard for the food industry.
A chemical nutritional analysis is not necessary or required by the FDA in most cases. A recipe, or database, analysis is generally an appropriate, and accurate, method of nutritional analysis for most types of food. There are also the added benefits of speed and economy with this method. The main concern with database analysis is that the results be truthful and not misleading compared to what the FDA would find when performing chemical analysis on the food. For database nutrition analysis the results are only as good as the recipe information provided to the analyst and the quality of the nutrient data used. When the information is good a database analysis can be as accurate and reliable as a chemical analysis of the food.
There are times when only a chemical nutrition analysis is appropriate. For instance, nutrient content claim substantiation over the shelf life of a product can only be done through chemical analysis in the laboratory. Chemical analysis is also necessary when other methods of nutritional analysis are not appropriate for the type of food or for the processing techniques used to make the food. Beef jerky is a classic example of a food that should be analyzed chemically for nutrient content. Often the process to make beef jerky includes a marinade that is discarded followed by a drying process where juices fall off of the jerky. This complicated process makes recipe analysis from a nutrient database inappropriate. Other types of foods where chemical nutritional analysis is recommended include fermented and/or cultured foods like kombucha, cheese or kimchi, pickled foods, and nut milk.