CFA submitted the following comments on the U.S. Food and Drug Administration’s proposed update to the definition for the implied nutrient content claim “healthy.” The comments express support for new rules that will to allow more whole food products to bear a “healthy” claim on the label. In general, the proposed changes to the “healthy” definition will assist consumers to make healthier choices by making clear that whole foods are the key building blocks of a healthy diet, and that consumers should avoid foods with high levels of added sugars, sodium, and saturated fat. However, the comments urge FDA to go further in restricting the definition as it applies to foods that pose a credible threat of causing diet-related disease among significant segments of the population, including fruit juice, and foods and beverages made with artificial or “high intensity” sweeteners.