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Is this an FDA labeling violation?


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DAVE84

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Posted 13 November 2011 - 05:32 PM

Hi all,

I have seen FDA violation like product contained few ingredients but they were not mentioned on label. But does anyone has experience with opposite case ? Product will not contain ingredient, but it will be mentioned on label.....

Does anyone has experience with this???
is that labeling violation?


Dave



ScottN_AMQA

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Posted 01 December 2011 - 01:55 PM

Hi all,

I have seen FDA violation like product contained few ingredients but they were not mentioned on label. But does anyone has experience with opposite case ? Product will not contain ingredient, but it will be mentioned on label.....

Does anyone has experience with this???
is that labeling violation?


Dave


Check the FDA labeling guidelines FDA Labeling and see if this answers your questions. In terms of meeting a GFSI standard you may not be meeting a legal responsability or nutritional claim. This also could potentialy fail or cause issues with tracability with your ingredients since it would affect your on hand inventory would not match the proposed used inventory (mass balance).


EEsterling

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Posted 15 December 2011 - 06:09 PM

I think there is specific evidence that that is NOT inherently an FDA violation. For purposes of food allergen declarations, manufacturers are allowed (encouraged?) to say if a food might contain an allergen. However, as the previous poster pointed out, it could become a violation if the declared ingredient is needed to meet nutritional claims. For example, declaring 30% of the DV for vitamin C, listing ingredients which might make that possible, but then not actually including those ingredients would be a violation.



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esquef

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Posted 20 December 2011 - 02:21 PM

I remember a recent FDA recall or 483 warning letter that involved a company making a product that had paprika on the ingredient panel but not in the formula.



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