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Labeling of Sub-ingredients

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Posted 25 January 2017 - 02:31 PM

When is it necessary to declare all sub ingredients for a product, specifically spice blends? For example, if a powdered product contains more than one ingredient and is used in a spice blend is it necessary to declare those sub ingredients in the final product label?


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Posted 25 January 2017 - 06:24 PM

Hi there!


Yes you do need to list sub ingredients, and FDA loves to hand out warning letters for companies that fail to do so for common ingredients like spice blends, cheese, or other items.


You can, however, combine sub-ingredients into FDA approved categories of "natural flavor", or  "spices", and they provide definitions for what components fit into those categories.

CFR for regulated definitions: http://www.accessdat...h.cfm?fr=501.22

Some FDA guidance policy: http://www.fda.gov/I...l/ucm074468.htm


As always, if it's a functional ingredient (like a preservative or anti-caking agent), MSG, or something that could be an allergen or sensitivity, it should be listed.

Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.


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Posted 01 February 2017 - 11:21 PM

In Australia, the rule is:

·         If an allergen

·         If a functional ingredient (preservatives, emulsifiers… if it has a number attached to it, you have to declare it). 


To give you an indication, attached are the items, as per the Australian Food Code.  

Attached Files

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