What is a qualified health claim?
A qualified health claim is a claim reviewed and issued by the FDA. Upon a rigorous review of scientific evidence provided, the FDA will issue a ‘Letter of Enforcement Discretion’ for a “qualified health claim” when emerging evidence is credible and compelling enough to suggest a link between a certain food and a specific health benefit, in this case yogurt and a reduced risk of type 2 diabetes. The FDA also imposes strict wording requirements on qualified health claims, both to reflect the amount of scientific evidence supporting that claim, and to convey any other necessary qualifications.
What does the science say about yogurt and diabetes?
The FDA reviewed all available evidence and drew conclusions from several observational studies, suggesting that yogurt consumption is linked to a reduced risk of type 2 diabetes. Many diseases, like type 2 diabetes, develop over time and not in a short window, making it difficult to observe this endpoint in a controlled intervention study. However, more randomized controlled trials would help understand more about the nature of this inverse association between yogurt consumption and type 2 diabetes risk.
Does this mean all dairy products get the claim?
No, this QHC is specifically for yogurt. The FDA has permitted it to be used on labels of products that meet the federal standard of identity for yogurt.
Why didn’t the FDA limit the claim to products with low added sugar?
The FDA did not limit the claim to products that only contain low amounts of added sugar, though they did encourage careful consideration of whether to use the claim on products that could contribute significant amounts of added sugars to the diet. Although some yogurts are higher in added sugar than others, yogurt as an overall category is not a primary contributor of added sugar in the American diet. According to the 2020-2025 Dietary Guidelines for Americans, the category of higher fat milk and yogurt is identified as providing only 4% of average added sugar intake, which would also include foods such as chocolate milk that typically have high amounts of added sugar.