Labeling of Sub-ingredients

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?

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.

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.