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Can we add another label on top of an incorrect label?


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#1 saenath

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Posted 23 November 2017 - 11:29 AM

Can we alter the lable on top of an incorrect label.

 

 


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#2 Charles.C

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Posted 24 November 2017 - 04:10 AM

Can we alter the lable on top of an incorrect label.

 

Hi saenath,

 

i presume "alter" = "add"

 

Not sure about UK but in many Countries this could result in  a Regulatory Rejection.


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Kind Regards,

 

Charles.C


#3 Tony-C

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Posted 24 November 2017 - 04:17 AM

That would be a no, no Saenath.

 

You need to fully remove the label if possible then relabel.

 

Kind regards,

 

Tony


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#4 tdunkley

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Posted 27 November 2017 - 01:48 AM

Also, if removal of the old label would make it look bad, or appear to be tampered with, then it's another clear "no", certainly from a retailer perspective. 


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#5 GMO

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Posted 13 December 2017 - 12:46 PM

As others have said, I would say "no". 

 

Interestingly I had a labelling issue last month where on a (non customer facing) pack had the correct "display until" date but had missed the words "display until" so I agreed they could have a second label with the words "display until" and the same date.  In my mind in any case, there could be no customer confusion but with a customer facing pack it always has to be a "no" for me.  Fully remove the label or strip completely if the label can't be removed.


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#6 FurFarmandFork

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Posted 13 December 2017 - 04:57 PM

FSIS actually permits stickers to correct issues, and I can't find it at the moment but I remember FDA being on the fence about it as well.

"Q34. If a pressure sensitive sticker is used to correct a label issue (e.g., nutrition facts panel error, allergen advisory declaration, etc.), may the sticker be applied generically or would the manufacturer be required to submit a temporary label approval in order to apply this sticker?

If a pressure sensitive sticker is applied to a label in order to correct a label error or deficiency, the label may be used with the sticker indefinitely.  However, if the sticker is used to add information to a label but does not correct the label to be fully compliant (e.g. adding an ingredient of public health concern but not placed in its proper order of predominance), then the establishment will need to correct it’s label or submit the label for a temporary approval to be able to keep using the incorrect label until the label can be replaced. "

 

 

The key point is that the sticker should completely cover/obscure any conflicting/replacement material, so placement is critical, and the sticker adhesive/backing should be strong enough that the sticker cannot be removed to expose the material underneath (i.e. it should tear and continue to cover what's underneath if someone were to pick at it).


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#7 GMO

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Posted 14 December 2017 - 08:21 AM

For sure, I have seen packs in the UK overstickered with different nutritional and ingredient information for the UK vs. the manufacturing country and it's legal to do that but IMO it is fraught with error and risk.  If only one pack is missed, it's a public recall and it does happen.


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