Can you over declare on labels and specifications
I am in the process of matching ingredient declarations on specifications with label declarations against Ingredient Logs and Recipes. In the past employees who have done this job and are no longer here said it is ok to over declare but not under declare. So an example is your product label and specification say Turmeric, Alum & Celery Seed but it's not in the recipe or on the Ingredient Logs when it is made. Is it ok to do this and how do you explain to an auditor if they were to ask? I have tried doing some research and haven't been able to find any information. Any help would be appreciated.
Thank You
Hi JPortz
No over declaring is not permitted and in fact would be illegal in many countries like it is in Australia.Some companies involve in such activities as they try to match there products with their competitors. If an ingredient is not in a recipe of a product then it should not be on the label of that product.
It is a serious offence in Australia. The Food Safety Authority can ask the manufacturer to recall the product if the find out that you labels have some ingredients which were not added to the product.
Kind regards
Dr. Humaid Khan
MD Halal International Services
Sydney Australia
We Work Globally
If your label query is in relation to possible allergen contamination, and not necessarily ingredients, you need to contact/research FDA/USDA labelling requirements. I would assume the "over declaring is ok" statement is coming from allergens in your facility.
I did ask the FDA and they sent me the following which doesn't clearly say. https://www.gpo.gov/...apIV-sec343.htm
I then responded that I still don't understand if you can under declare or over declare and they said the following. Labeling is required to be truthful and not misleading. So if you are over declaring, I take that as misleading?
That would be the stance I take, further more if you are declaring an ingredient that is NOT included in the product nor is there a concern about cross contamination you're eliminating a potential customer without cause. Have you done a recent audit on your vendors, perhaps the product USED TO contain those ingredients or there was a risk of them being included. in anycase, if you're taking over where someone else left off, do not assume things were done correctly! Get new C of A from your suppliers if you haven't already done so.
FYI in Canada mis leading labelling comes with a hefty fine