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Nutrition labels are inaccurate. This is why. And, here are our estimates.

written by

Marie Reedell

posted on

January 27, 2023

In the food industry, nutrition labels are voluntary. If you’ve bought one of our products, then you know that we choose to NOT include nutrition labels. There are a few reasons why:

  1. We don’t want to spend extra money on testing and label approval and then pass that cost along to you. It costs about $800-1000 per sample.
  2. We don’t want to spend extra time on testing. We’d rather focus on being an amazing and reliable source for the highest quality farm direct, nutrient dense food.
  3. Nutrition labels are notoriously inaccurate.

Let’s dive deeper into that last point.

The FDA allows up to 20% difference between what’s on the nutrition label and what’s accurate. Yes, you read that correctly. The nutrition labels are not required to be accurate. And the rules change based on the type of nutrients.

Class I nutrients are those in fortified or fabricated foods. This happens when milk is fortified with vitamin D, when orange juice is fortified with vitamin C, or when cereal is fortified with fiber. Class I nutrients must be present at 100% or more of the declared value on the label.

For example, if a product states that it has 2.7mcg/serving of vitamin D, then the lab test must show 2.7mcg/serving or more to be in compliance. It could be 10 or 100 or 1000mcg/serving and still be in compliance.

Class II nutrients are naturally occurring nutrients, present in the food because that’s what the food naturally contains. In other words, vitamins, minerals, protein, carbohydrate, dietary fiber, fat, etc that are present in the food without fortification. Class II nutrients must be present at 80% or more of the declared value.

Let’s take Vitamin C as an example. Let’s say that the nutrition label says that there is 6mg/serving of Vitamin C naturally occurring in the food. When the product is tested, as long as there is at least 4.8mg/serving (80% of 6mg), then the label is in compliance.

Lastly, there are the Third Group nutrients, which include calories, sugars, total fat, saturated fat, cholesterol, and sodium. Third Ground nutrients must have a lab analysis that’s 120% or less of the declared value.

For example, let’s say a product claims 6g of total fat per serving. The lab test must show no more than 7.2g of total fat per serving (20% more than 6g). It could have 3 or 5 or 7g and still be in compliance.

So, right from the start, you can see how this is tricky. Nutrition facts are estimates. And now it gets more complicated.

Oftentimes, foods aren’t actually being tested. The ingredients are sent to a bot, and the bot shoots out FDA-compliant nutrition facts.

Companies, especially small businesses like us, may want to avoid the $800-1000 fee for testing one sample. Or, they might want to speed up the process; you can get the results back from the bot instantly.

The way it works is you enter your recipe into a nutrition fact generator. You’d type in 1 cup flour, ½ cup butter, 1lb ground beef, 2 tsp salt, etc. And then, magically, it gives you a nutrition label! It uses its database of ingredients to do this.

Of course this isn’t accurate. It’s obviously an estimate. And, it’s a wild estimate for a company like Miller’s that’s producing natural foods with varying nutritional profiles. 

The nutritional profile of food changes with the soil, the farming practices, the season, and the batch.

Soil matters. There’s a big difference in the nutritional value of a carrot grown in the 1920s when topsoil was deep and healthy and a carrot grown today in depleted soil topped with synthetic fertilizers. 

Farming practices matter. There’s a big nutritional difference between conventional beef that’s fed GMO corn and soy and 100% grass-fed, regeneratively farmed beef. 

The season matters. Spring milk, when the cows first start eating 100% spring grass, is yellower and more nutrient dense than milk from the winter, when the cows are eating 100% dry pasture.

The batch matters. Miller’s products are artisanally made in small batches. Yes, we use machines, but there’s a lot of hand work involved, too. The time of fermentation, the pH, the amount the bone broth cooks down, and so on are all a little variable. There’s a human element that decides when it’s “done”. We do our best to keep things consistent, but each batch has a unique flavor, texture, and nutritional value.

Despite all of the above, I know that counting calories or macros (or other things) is important to some people, especially those trying to heal or improve their health. So, I made a little guide.

The new Real Foods Nutrition Facts Guide is mostly based on estimates, comparing our products to similar store bought products that do have nutrition labels. Some of the data is very accurate. For example, the amount of sodium in the cheese has been calculated.

And, right now, it only contains dairy, eggs, and meat. I will likely add more as customers request it.

📙 Check out the new Real Foods Nutrition Facts Guide here

What do you think about nutrition labels? Do you rely on them? If yes, why? If no, why not?

I’d love to hear from you. Comment below (no account required - start typing for the guest option to appear) or contact us.

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Sources

  1. Guidance for Industry: Guide for Developing and Using Data Bases for Nutrition Labeling
  2. ReciPal

Health and Nutrition

Opinion

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Raw milk or fermented dairy and lactose intolerance. Why might it help?

I was misinformed. At some point, I read that raw milk contains lactase. As it turns out, this is not true! It is true that raw milk contains many live enzymes that are inactivated during pasteurization. But, what about lactase? I’ve heard many anecdotal stories from people who are lactose intolerant... but can handle raw milk or fermented dairy. If raw milk, yogurt, kefir, or cheese doesn’t contain lactase, then why is that?

Our bone broth tested negative-ish for heavy metals 🥳 NATURAL AND CLEAN

Over the past few months a bunch of people asked us if we tested our bone broth for toxic heavy metals. When we get the same question a lot, we of course look into it. My first question was --- Is there an issue with toxic metals in bone broth? As it turns out, yes, there "can" be an issue! Heavy metals are naturally present in our environment. We need the "good" heavy metals to thrive: iron, zinc, magnesium, copper, etc. But, we can 100% do without the toxic heavy metals: arsenic, cadmium, lead, mercury, etc. Too many toxic heavy metals can lead to a host of pretty awful issues: nervous system damage, cardiovascular issues, cancer, endocrine disruption, kidney damage, and so on. Our body is designed to excrete heavy metals through urine (and a little bit through sweat, hair, and breastmilk too)... but only so much. There's a limit. If you're overloaded, your body will store those heavy metals in your bones, blood, tissues, and organs. Similarly, if an animal is exposed to heavy metals via food, water, air, dust, or soil, those heavy metals accumulate in the bones. Maybe the farm's soil or air is contaminated from a nearby factory. Maybe the pipes for the water has lead solder connecting them. Maybe the feed a farm is buying was grown on contaminated soil or processed on contaminated equipment.  And, of course, a main purpose of bone broth is drawing out as much as possible from the bones. If there are heavy metals in bones, they will make their way into the broth. This is especially true when you pre-soak with apple cider vinegar and simmer for 48 hours to make it thick and gelatinous (like our broth). And that led me to my second question --- Should I be concerned about every bone broth? Where is the fear coming from? Well... it seems it might be a little political. There was a study done in the UK in 2013 that scared a lot of people. It's titled "The Risk of Lead Contamination in Bone Broth Diets". This study found high levels of lead in organic chicken bone broth, which is quite concerning. And, in fact, this one study is still cited in articles written today! Let's dig a little deeper. Let's go farther than the short abstract. Here are the broths tested in the study and their test results for lead:  (9.5 parts per billion): Broth made from tap water plus skin and cartilage(7.01 parts per billion): Broth made from tap water plus bones(2.3 parts per billion): Broth made from tap water plus meat(0.89 parts per billion): Tap water alone cooked for the same amount of time as a control. But, they only used organic chicken from one farm. And, there's zero information about that farm, their practices, the feed, and the broth recipe. Did they use vinegar or wine in the broth? Was the chicken's water contaminated with lead? What was the quality of the feed and the soil? Were the chickens raised indoors or outdoors? So many unanswered questions! All we get is that it was one "organic chicken" that created a lead issue with broth. Another curious thing is that the broth with skin and cartilage contained more lead than the broth made with just bones. Bones are where lead is stored, so why wouldn't the broth made with bones only contain more lead? It's an odd result. Moreover, the abstract of the study specifically called out "bone broth diets" like GAPS and paleo. They even go so far as to write, "In view of the dangers of lead consumption to the human body, we recommend that doctors and nutritionists take the risk of lead contamination into consideration when advising patients about bone broth diets." That's quite curious. Why are they worried about these diets? Are the researchers anti healing through food? Who funded the research? Is it political? My opinion? This study is not comprehensive. It does not speak to all bone broths. But it does cover a potential issue if the water or animals are overloaded with heavy metals. What I glean from this study is that we need more research. We don't need fear to spread and people to stop drinking broth from this one study. Regardless of whether the fear was fabricated or legit, we tested our bone broth anyway. After all, it's always nice to validate that your food choices are as clean as you think. For Miller's, here were my concerns before testing: What if there's mercury in the fishmeal in our chicken feed?What if the soil that our animals live on is contaminated?What is the well water that the broth is made with is contaminated?What if the Celtic sea salt has lots of heavy metals? We got the test results back. I was super excited. But, I was also confused. At face value, it appeared that our bone broth tested NEGATIVE for arsenic, cadmium, lead, and mercury. You can find the test results right here! You'll notice that, for every sample, the results are "<0.01 mg/kg" and "<0.02 mg/kg".  I asked the lab what the "<" means. They said that it indicates their limit of quantitation (LOQ), the lowest concentration that can be accurately tested using the test procedure in that sample type. So the results simply report that none of the metals tested were found in the sample above the specific reporting LOQs. Whether or not they were present below this LOQ is information that is not provided by the test. When talking to the lab, I told them what we needed and assumed that this test would go below a 1 ppb. So, when the results came in, I assumed that a "mg/kg" was the same as a part per billion (ppb). Ummm... that math wasn't write! A "mg/kg" is actually a part per million (ppm). That means that the test we ran had results saying that the broth had less than 0.02 ppm (or 20 ppb) of arsenic and lead. And, it had less than 0.01 ppm (or 10 ppb) of cadmium and mercury. For some reference, the EPA says that less than 15 ppb of lead is safe in drinking water. Not saying that I agree, but it's a good reference point.  These results are good. It means the broth definitely isn't overloaded with toxic heavy metals. But, it's not good enough!!! We need to test again! We really need to a lower LOQ. We need to know the results with an accuracy of as low as 1 ppb. It looks like the lab we sent the original samples to doesn't have an LOQ that low. So here I am on the hunt for a lab to do it again. As soon as I can, I'll send samples in again and paying for more expensive testing to get the info you deserve. Stay tuned! I hope to have the new results in by the end of April 2025. Do you worry about toxic metals (or other junk) in your food? Where have your fears stemmed from? I'd love to hear from you. You can comment below (no account required) or contact us 😊 ----- Sources The risk of lead contamination in bone broth dietsBone Broth and Lead Toxicity: Should You Be Concerned?Bone Broth and Lead Contamination: A Very Flawed Study in Medical HypothesesBone Broth, Collagen, and Toxic Metals: A Research Review