Can you say "healthy" on your food label? the new FDA rule, explained

This is the opposite situation from the front-of-package rule, which is still only proposed and has no deadline at all. This one is real, it is on the books, and it has a date.

Status box

Last reviewed: August 2, 2026.

The effective date moved once. FDA originally set it at February 25, 2025, then pushed it to April 28, 2025 under the January 20, 2025 regulatory freeze memorandum. The compliance date did not move. See the delay notice and the final rule.

First, the thing most people miss

Using "healthy" is voluntary. Nobody makes you.

But the moment you use it, you have made a nutrient content claim, and that changes your obligations far beyond this one rule. "Healthy" is an implied nutrient content claim under 21 CFR 101.65. And a nutrient content claim voids the FDA small business labeling exemption under 21 CFR 101.9(j)(18).

So if you're a small operation that currently ships without a Nutrition Facts panel because you're under 100 employees and 100,000 units, putting "healthy" on the jar takes that exemption away. You now need a full compliant panel. The exemption is void whether the claim appears on the label, in your labeling, or in your advertising. A "healthy" in your Instagram bio or on your Shopify product page counts.

Full detail on that trap: nutrient content claims that void your labeling exemption.

What changed, and why some foods flipped

The old definition dated to 1994. It capped total fat, saturated fat, cholesterol, and sodium, and it required the food to deliver at least 10% DV of one of six nutrients: vitamin A, vitamin C, calcium, iron, protein, or fiber.

That produced results nobody could defend. Because total fat was capped, almonds, salmon, and olive oil could not be called healthy. Because a 10% DV of a fortified nutrient was enough, sugary fortified cereal and fortified white bread could. The rule rewarded fortification and punished whole foods.

The new rule drops the total fat cap, drops the cholesterol cap, drops the fortification-driven nutrient minimum, and adds two things: a food group requirement and an added sugars limit.

Newly eligible: nuts, seeds, higher-fat fish such as salmon, certain oils including olive oil, avocado, eggs, and plain water.

Losing eligibility as of February 25, 2028: fortified white bread, highly sweetened cereals, fortified fruit punch, sweetened yogurts, and high-added-sugar fruit snacks.

If you sell anything in that second group and you've been leaning on "healthy," you have a reformulation decision, not a labeling decision. That's why the 2028 date matters.

The actual criteria

Two tests. You have to pass both.

Test 1: the food group equivalent

Your product has to contain a minimum amount from at least one recommended food group. FDA calls the unit a food group equivalent (FGE).

Test 2: the nutrient limits

Caps on added sugars, sodium, and saturated fat, expressed as percent Daily Value. The caps loosen as the product gets bigger and more composite, because a full meal legitimately carries more of everything than a single ingredient does.

Individual foods (RACC greater than 50g or 3 tablespoons):

For products with a RACC of 50g or less, or 3 tablespoons or less, the same requirements apply on a per-50g basis.

Composite products:

Mixed products are measured per RACC. Main dishes and meals are measured per labeled serving.

The shortcut list

Some foods qualify automatically, with no FGE math and no nutrient calculation:

• Raw whole fruits and vegetables
• Whole grains, fat-free and low-fat dairy, lean meat, seafood, eggs, beans, lentils, nuts, and seeds, where water is the only added ingredient
• Water, plain tea, and plain coffee at less than 5 calories per RACC and per labeled serving

Add salt, oil, or sugar to any of those and you leave the shortcut and go back to the tables.

How a small brand figures out whether it qualifies

Here is the practical version, and notice what it reduces to.

Step 1. Classify your product. Individual food, mixed product, main dish, or meal? A jar of salsa is an individual food or a mixed product. A frozen burrito is a main dish. A frozen dinner with three components is a meal. This determines which row of the table applies, and the rows differ by a lot. Getting this wrong is the most common way to reach a wrong answer.

Step 2. Get your RACC right. Every threshold is per RACC or per labeled serving, and your RACC is not your choice. It comes from the reference amount table at 21 CFR 101.12. If your serving size is wrong, every percent DV below it is wrong, and your qualification answer is wrong.

Step 3. Pull your three numbers. Added sugars, sodium, and saturated fat, as percent Daily Value per serving. Compare them against your row.

Step 4. Count your food group equivalent. How much actual vegetable, fruit, whole grain, dairy, or protein is in one serving? Not "contains tomatoes." A measured half-cup equivalent.

Steps 2 and 3 are the whole difficulty, and they are not a "healthy" problem. They are a do you know your numbers problem. If you have a correctly built Nutrition Facts panel with the right RACC, you can answer the nutrient half of this in about five minutes with the table above. If you don't, you cannot answer it at all, and no amount of reading about the rule will change that.

If you need the panel itself, Nutrillius builds an FDA-compliant Nutrition Facts panel from your recipe in about a minute, with the RACC pulled from 21 CFR 101.12 rather than guessed. $39 one time, no subscription.

The "healthy" symbol

FDA has said it is developing a voluntary graphic symbol that manufacturers could put on packages to signal the product meets the "healthy" definition. Preliminary consumer research has been done.

As of August 2, 2026, no symbol has been released. There is no approved artwork, no specification, and nothing to put on a package. If someone offers to sell you a "healthy" badge for your label, there is no such thing yet. The claim is currently a word, not a mark.