In From Label to Table: Regulating Food in America in the Information Age, Xaq Frolich takes a metacognitive approach to food history. Why do we ask particular questions and not others about what we eat? Most of the time daily consumers are too focused on what is in or not in our food materially to think about what might not be in the messaging about our food. Which questions are we not asking? In six densely informational chapters with an introduction and conclusion, Frolich provides a chronological account of changes in food labeling in the US through the twentieth century. Each chapter focuses on a particular approach to labeling and is set in the context of the contemporary discourse about food and industry.

Frolich builds on and synthesizes a robust scholarship about food regulation and consumer culture, such as the groundbreaking Consumer’s Republic by Lizabeth Cohen and the more recent study of the Food and Drug Administration (FDA), Jonathan Rees’s The Chemistry of Fear: Harvey Wiley’s Fight for Pure Food. He uses contemporary reporting on changes to dietary rules as well as FDA internal reports to reconstruct the logic and constraints of each era and each significant change in thinking and communications. The FDA’s constant policing of the boundary between food and drugs is a throughline in this narrative. Claims could be made for the latter that could not legally be made for the former. This dichotomy, however, is always conceptually blurry because humans have used food as medicine for as long as we have records of what people ate and why.

Frolich reveals that in food markets what may be conceived of as a dialogue between producer and consumer is actually a three-way conversation, mediated by the FDA, which itself does not speak as one voice but also represents a variety of interests. The FDA can be influenced by lobbyists and consumer groups as well as by its own staff’s evolving research findings.

Nutrition and dietetics researchers in the early twentieth century helped to identify the essential elements of a “healthy” diet, which is itself a social construct. In practice this meant that nutritionists and dieticians looked for what was lacking in American diets and sought ways to supply it. This led to fortification of some items, such as wheat flour, but also to concentrated advice on how to get all necessary nutrients by selecting the correct diet. Food companies were largely unregulated in the way they communicated the ingredients of their products and often made exaggerated claims about the benefits of their products. The FDA paid attention to these claims when they seemed to cross the food–drug boundary.

Rather than regulating the ingredients of finished products, Frolich explains, the FDA established “identity standards” for common items, such as tomato juice. To wear the label, a product had to conform to this standard. Otherwise, it had to use the term “imitation” to denote its distance from the real thing. This led to absurdity at times, as when a frozen dessert clearly marked “not ice cream” had to cease distribution until it could produce a label declaring it “imitation ice cream” (p. 40). Although it is not the focus of Frolich’s research, it is interesting to consider the implications of the identity standards for the construction of a national cuisine. Another scholar might usefully ask how much identity standards were proscriptive and how much they were descriptive of contemporary foodways.

By 1938, the FDA required food producers to list ingredients on packaging in order of weight, leaving it to consumers to decide whether they trusted the product on the basis of this information. This constructed the concept of the “ordinary” consumer as needing information but not protection. Ingredients lists, however, did not always reassure consumers as they became aware of how much they did not know about ingredients and production of the food in an increasingly industrialized food system. Producers were anxious about the exposure these labels required, while consumers did not feel they showed enough. Frolich is adept at showing readers the competing interests and fears that shaped the kind of information available to the public about its food.

Soon after the end of the Second World War, the central theme of governmental food communications changed radically, from deficiency to surplus. Where pre-war diets had been notable for what they lacked, the diets of post-war prosperity seemed dangerous for what they included. As US Department of Agriculture (USDA) nutritionists and dieticians began to sound the note of caution about fats, sugar, and salt, food industry leaders were suddenly much more interested in communicating with the FDA. To prevent the demonization of their products, they employed lobbyists to review labeling rules and had a remarkably consistent record of getting messages changed in ways that favored industry.

In the 1950s the FDA employed the new strategies of consumer psychology to try to understand what kind of information consumers could take in without becoming confused. Food industry producers would need to present their products to the public in ways that made clear any risks of consumption. This protective philosophy was clearest in the 1962 Consumer’s Bill of Rights. Food industry leaders fought back against the implication that industry was predatory, and by 1973, they had made significant headway. Frolich identifies 1973 as a watershed moment, when the FDA moved away from a protective stance and once again constructed consumers as responsible for their own choices. Food labeling now needed to present nutritional values in a numerical form. Consumers could read or ignore this information as they pleased, but responsibility for the health impacts rested with them, not with the FDA or the producer. This rhetorical construction of consumers as solely responsible for their choices then enabled the vote-with-your-fork politics of twenty-first century American food culture. For those unhappy with this regime, Frolich offers the useful reminder in his conclusion that “regulation is relational,” not inevitable (p. 194).