What can be learned from others about front-of-package labeling? What can be learned from others about front-of-package labeling?

In 2016, Chile became the first country to introduce nutrient warning labels on processed foods and beverages as part of a comprehensive package to reduce childhood obesity that also included marketing and school-based restrictions. The policy was phased in with increasingly strict nutritional criteria over time.

Warning label design in Chile. Source: Ley Nº 20.606 – Ley sobre composición nutricional de los alimentos y su publicidad

https://vimeo.com/1199834795

Watch: Global Food Research Program at UNC-Chapel Hill’s short film that highlights the policy process and its results.

The Rigorous Research Process

Chile first proposed the UK’s traffic-light labeling system, but testing showed Chileans had trouble understanding it.  A multidisciplinary team—public health experts, nutritionists, food labeling specialists, marketers and designers—joined forces to research a new approach, with steps including:

1. Literature review—Expanded beyond food labeling to include alcohol and tobacco warning labels, which had stronger evidence bases.
2. Focus groups—Women and adolescents from low-middle socioeconomic backgrounds provided feedback on text and design options in six groups.
3. Experts consulted—A group of 50+ diverse experts refined prototypes, selecting 15 food warning label designs for quantitative testing.
4. Two quantitative studies at point-of-sale:
   1. Study 1: 600 women selected two top prototypes, which were displayed on yogurt and shown to 40 women at supermarkets in low- and middle-income Santiago neighborhoods. Participants completed surveys about understanding and purchase intentions.
   2. Study 2: 700 women identified which prototype performed better on outcomes including understanding and ability to shift purchase behavior. To assess performance among lower-income populations, 600 adolescents and women were interviewed at supermarkets in low-income neighborhoods.

The Winning Design

In 2016, Chile introduced the top-performing label: a black and white octagon that warned of high content of nutrients or ingredients of concern. Though “excess” tested better with consumers, the law’s wording required that “high in” be used instead. Other countries have since successfully used “excess.” Chile banned use of “high in” in positive marketing (e.g., “high in vitamins”) and launched a public campaign to explain the labels.

Global Influence

Chile’s model has been adapted in countries across Latin America and beyond.

Source: Global Food Research Program at UNC-Chapel Hill. Maps: Front-of-package labels: Mandatory nutrient warnings.

Impact

Evaluations show Chile’s warning labels have successfully deterred unhealthy food choices and reduced purchases.

➔ See Food Policy Hub case study “How Chile Rigorously Evaluates Its Food Policy Law and Provides Critical Data for Other Countries.”

Key Takeaways

• Nutrient warning labels use an evidence-based design adapted from alcohol and tobacco strategies, refined through expert consultation and rigorous testing with low-income populations.
• Successfully adapted across countries in Latin America and beyond, validating the model’s effectiveness.
• Sufficient evidence exists to support implementation when research resources are constrained, though local testing remains ideal.

Policy Snapshot

Brazil’s Health Regulatory Agency (ANVISA) approved mandatory front-of-package warning labels using a magnifying glass design for products high in sugar, saturated fats and sodium (October 2020, implemented October 2022).

Source: Global Health Advocacy Incubator. Brazil Implements Front-of-Package Warning Labels.

Key strengths

• Black and white “high in” labels placed on top of packages
• Focuses on ultra-processed products; excludes fresh and minimally processed foods
• Prohibits competing labeling models and nutrition claims for warned nutrients
• Standardized nutritional facts table with information per 100g/100ml

Remaining challenges

• Label size smaller than evidence recommended
• Nutrient profile model weaker than PAHO recommendations
• No warning labels for nonsugar sweeteners, likely leading to product reformulation with sweeteners

Advocates continue pushing for more stringent requirements, including a stronger nutrient profile model.

Policy Timeline

The Brazilian Alliance for Adequate and Healthy Eating (Aliança pela Alimentação Adequada e Saudável)—a coalition of civil society organizations and academics—was paramount in advancing front-of-package labeling in Brazil. The Alliance launched multi-faceted campaigns combining digital media, traditional media, earned media, influencer engagement and community activities at strategic points in the policy process.

2016: Regulatory Review Begins

• Brazil’s Health Regulatory Agency (ANVISA) began reviewing nutrition label regulations, which food and beverage industry sectors tried to water down from the beginning.
• The Brazilian Institute for Consumer Protection (IDEC) ramped up advocacy efforts, building public support for clearer labels and recognizing the need for organized, consistent civil society action.

2017: Setting the Agenda

• The Alliance launched the “Right to Know” mass media and advocacy campaign, making the case for food warning labels and setting the policy agenda.

2018: Prompting Public Input

• The campaign called for a public consultation, prompting ANVISA to initiate one in 2019.

2019: Record-Breaking Public Participation

• ANVISA launched a digital campaign to encourage public participation. The consultation received a record 23,400 contributions.
• The agribusiness sector requested deadline extensions and argued the regulation would harm the economy.

2020: Final Push Amid Political Challenges

• IDEC used judicial means to ensure completion of the regulatory process, filing a lawsuit to keep it moving forward. IDEC demonstrated the region’s front-of-package labeling advances and mapped out possible industry interference scenarios.
• The Alliance launched a final advocacy campaign pushing ANVISA to make a decision.
• The new regulation (RDC 429/2020) was approved in October 2020, calling for warning labels using a magnifying glass design.

Members of the Alliance for an Adequate and Healthy Diet, a civil society coalition in Brazil, push Brazil’s National Health Surveillance Agency to approve food warning labels. Source: Jéssica Ribeiro: What’s in Our Food? A guide to introducing front-of-package nutrient labels

Key Success Factors

• Strategic timing of campaigns at critical decision points throughout the multi-year policy process
• Coalition power uniting civil society organizations and academics to counter organized industry opposition
• Evidence-based advocacy free of conflicts of interest, demonstrating the problem and maintaining pressure on ANVISA for transparency
• Regional context highlighting advances in front-of-package labeling across Latin America to demonstrate feasibility and build urgency
• Sustained mobilization maintaining pressure from initial agenda-setting through implementation and beyond

Source: IDEC/Aliança pela Alimentação Adequada e Saudável

Chile’s comprehensive food policy law—the first to include nutrient warning labels—has been rigorously evaluated, providing crucial evidence for policymakers worldwide.

Evaluation Findings

Measuring Compliance (Process Evaluation)

After Phase 1 (2017): The Ministry of Health conducted more than 3,000 inspections at food distribution companies, supermarkets and schools. More than 70% of institutions complied with regulations; the Ministry sought penalties for the 30% that did not.

After Phase 3 (2020): Trained dietitians visited Chilean supermarkets to assess labeling compliance. They found 94% of products that should carry warning labels actually displayed them.

Measuring Behavior Change (Outcome Evaluation)

After Phase 1 (2017): A representative survey by the University of Chile found that 92% of people thought the labeling policy was good regulation. Among the 44% who compared food warning labels when shopping, more than 90% said labels influenced their purchasing decisions.

Researchers analyzed purchases from 2,381 Chilean households before (2015) and after the law. Compared to pre-policy trends, the nutrient content from high-in products purchased by households declined:

• 24% fewer calories
• 37% less sodium
• 27% fewer calories from sugar

After Phase 2 (2019): A follow-up study evaluated purchases from 2,844 Chilean households before (2013) and after phase 2. Using similar methods, researchers found that households bought fewer calories, sodium, sugar and saturated fat from high-in products with warning labels.

• 23% fewer calories
• 22% less sodium
• 37% less sugar
• 16% less saturated fat

Changes were more pronounced during phase 2 of the law and were similar across socioeconomic groups.

Measuring Dietary Change (Impact Evaluation)

After Phase 1 (2017): A study of 300,000 Chilean schoolchildren aged 4–6 found that Phase 1 of the policy was associated with a lower probability of excess weight after six months of exposure (1.91% lower among girls, 2.24% among boys) that was even higher after 18 months (2.85% lower among girls, 2.40% among boys).

Countering Industry Misinformation

The food and beverage industry has pointed to Chile’s rising obesity rates to claim warning labels haven’t worked. However, it can take many years for healthy eating interventions to reduce obesity rates at the population level.

This highlights the importance of:

• Setting policy objectives that are measurable in the near term (such as purchasing behavior changes)
• Clearly communicating to stakeholders what can and cannot be measured within certain timeframes

➔ Learn about types of evaluations to measure policy adherence and impact

Key Takeaways

• Government-academic partnerships enabled comprehensive evaluation across compliance and outcome metrics
• Multiple evaluation approaches combining surveys, purchasing data analysis, and compliance inspections provided robust evidence from different angles
• Global influence as Chile’s rigorous evaluation data has been used by advocates worldwide to build the case for similar policies

In October 2019, Mexico’s Congress amended the General Health Law to mandate front-of-package warning labels, replacing the industry-backed Guideline Daily Amount labels. The implementing regulation was finalized in March 2020, and the labels went into effect in October 2020.

Final Policy Design

The final design uses black octagonal labels with “excess” warnings for calories, sugars, sodium, saturated fats, and trans fats, plus precautionary legends for added caffeine and nonsugar sweeteners that are not recommended for children. Another innovation of the Mexican labeling system is the use of numeric labels for packages with smaller display surfaces.

Translation (from left to right): Excess calories, Excess sugars, Excess saturated fats, Excess trans fats, Excess sodium (all with “Secretary of Health” at the bottom). Contains nonsugar sweeteners—not recommended for children. Contains caffeine—avoid in children. Source: Mexico’s Official Standard NOM-051-SCFI/SSA1-2010 (modified March 2020).

Key Strengths

• Octagonal warning labels using “excess” language, which research suggests increases perceptions of product unhealthfulness compared to “high in” labels.
• First country to adapt a nutrient profile model based on PAHO’s model, incorporating additional thresholds for calories and sodium, as well as criteria for critical ingredients such as added caffeine.
• First to add precautionary legends about caffeine and nonsugar sweeteners for children, anticipating potential reformulation strategies observed after Chile’s law.
• Restrictions on health claims, cartoon characters, brand mascots, celebrities, sports and animations directed at children on products carrying warning labels or nonsugar sweetener legends.
• Closed the “mini junk (chatarra)” loophole: small packages must display numbered octagons indicating total warnings, preventing industry from using miniature sizes to evade regulations.

Remaining Challenges

• Ensuring caffeine and nonsugar sweetener precautionary legends remain visible and legible across all package sizes and formats.
• Strengthening enforcement to prevent industry practices that obscure warnings.
• Phase three, the strictest implementation phase, would require products to be evaluated across all nutrients of concern when they contain added sugars, fats or sodium. This could particularly expand warning label coverage on ultra-processed dairy products. After successive postponements, phase 3 is now scheduled for Jan.1, 2028.

Advocates continue pushing for more stringent requirements based on these identified gaps.

Timeline

2011-2016: Building the Evidence

• Public health advocates opposed the industry-designed Global Daily Amounts (GDA) label because it was not evidence-based and lacked transparent development with independent public health experts.
• Civil society groups filed a high-profile legal case against the government (ultimately unsuccessful) and partnered with academics to evaluate label effectiveness.
• Questions on GDA comprehension were inserted into the national nutrition survey, revealing 98% of respondents were unaware of appropriate calorie intake for children aged 10-12, and 66% never used the label for purchases.
• These efforts received widespread media attention, building public awareness of the labeling system’s inadequacy.

2016-2019: Learning from Chile and Coordinating Advocacy

• Following Chile’s 2016 warning label enactment, Mexican civil society intensified reform efforts. The Mexican National Institute of Public Health convened experts from multiple disciplines to develop Mexico’s warning label proposal, drawing on regional evidence and implementation lessons.
• Civil society organizations—including La Alianza por la Salud Alimentaria and member El Poder del Consumidor—launched mass media campaigns to build support throughout 2018-2019.

Source: Let’s Demand Clear Labels (Exijamos etiquetados claros), Alianza por la Salud Alimentaria.

2019-2020: Political Window and Regulatory Approval

• The 2018 election of President López Obrador’s government created a political window for health policies.
• The government published a draft regulation in October 2019, generating 5,200 public comments—the most for any Mexican norm in history.
• Despite industry legal challenges and requests to delay implementation during the COVID-19 pandemic after the regulation was published in March 2020, it went into effect in October 2020 as planned, with sanctions applied beginning December 2020.

2020-2024: Strategic Legal Defense: A Rights-Based Approach

• The food and beverage industry filed more than 157 constitutional challenges (amparos) against the regulation.
• As major amparo cases move toward Supreme Court review, civil society coordinated unprecedented legal mobilization.
• El Poder del Consumidor and Alianza por la Salud Alimentaria submitted amicus briefs and compiled a public repository documenting international amicus briefs, expert statements and academic publications. The briefs emphasized Mexico’s front-of-package warning label system is evidence-based, conflict-free and aligned with the rights to health, adequate food, information and consumer and child protection.
• This coordinated effort framed the policy as essential to Mexico’s constitutional obligations. In April 2024, the Supreme Court unanimously upheld the constitutionality of key provisions, affirming that warning labels protect the rights to health and nutritious food, consumer information and children’s best interest.

Key Success Factors

• Evidence-based approach documenting the shortcomings of the previous labeling system and informing new design
• Regional learning from Chile’s model and other countries’ experiences
• Strong, coordinated civil society and academic coalition
• Proactive, rights-based legal framework positioning the policy as essential to constitutional obligations and the protection of children’s rights
• International backing through UN, UNICEF, PAHO, WHO and global amicus briefs countering industry opposition
• Strategic coordination of international legal support across industry challenges