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Labeling Requirements

Labeling Regulatory BRC FDA

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#1 marc40

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Posted 07 June 2018 - 05:26 PM

Hello Everyone, 

 

I'm hoping to gain some insight on labeling requirements for bulk processors. We are an almond processor and sell our product in 2200lb bins/sacks or 50lb boxes/bags for further processing. With regards to FDA and BRC what are the minimum labeling requirements? We already print company name and address, weight, product (almonds), unpasteurized/pasteurized, country of origin and description of product (size and type). I'm most interested in the size and type area. We have a customer requesting that we do not include this information. I feel like this would be okay, as the product as a whole would still be included (almonds) just not the specifics of it? Perhaps we're over thinking it, but better to be safe I suppose. Also, I realize this could depend on the destination; EU, Australia, etc. Still can't imagine the type and size being a legal requirement. Any references? 

 

Thanks So Much,

 

Marc

 

 

P.S. We just passed our first BRC audit with an A (7 NC's). Should have been a AA, couple obvious oversights...next time for sure. Thanks to all of you contributing to this network. It was a huge help in preparing for the audit. 



#2 Scampi

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Posted 07 June 2018 - 07:18 PM

www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=101&showFR=1&subpartNode=21:2.0.1.1.2.7

 

I just skimmed this part of the code, but I think you are off the hook if the container is labelled "for further processing" and is shipped in packaging that IS NOT FOR RETAIL sale

 

Congrats on your Audit!!!


Because we always have is never an appropriate response!


#3 Gerard H.

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Posted 08 June 2018 - 08:21 AM

Dear Marc,

 

The size and the type of the almonds are, in my best knowlegde, no legal declaration requirements. However, with the current developments on food fraud and the focus of BRC on this topic, it would be actually a good thing to declare these two aspects. 

 

Important in the minimum declaration are:

  • The identity of product and the unique batch coding
  • Shelf life of the product
  • Storage conditions

I hope to have informed you sufficiently.

 

Kind regards,

 

Gerard Heerkens







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