Raw Sausage Casings- include on ingredient statement?

Good morning, all.

We product raw sausage and I was wondering if the casing the sausage is packed in needs to be included in the ingredient statement? The only ruling I could find was 9 CFR Parts 317 and 381 [docket no. 94-030F] (linked below). The basic summary of this ruling was that if a sausage is packed in a casing derived from a different type of meat/poultry than what the sausage is made out of, that information must be disclosed on the label. We do mark the label as "Packed In A *insert casing type, eg Natural Hog or Collagen* Casing" but do not have it listed in the ingredient statement. It is, however, included in the ingredient statement on the Spec Sheets for each product. There have been no issues that have arose from this, however I would like to ensure we are up to snuff on regulations (USA) and industry standards.

Should I change the ingredient statement on the label to include the casing, or should I update the specs to remove the casing from the ingredient statement and just add a "Packed In XX Casings" section?

Thanks for any and all replies!

And to my US comrades, enjoy your holiday! I know this time of year is quit stressful, especially for those of us in the meat industry. Enjoy your hard earned day off!

Ricky 

 9 CFR Parts 317 and 381 [docket no. 94-030F]:

https://www.fsis.usd...pdf?MOD=AJPERES

Here is the actual law; looks like what you're currently doing is above board!  Happy Thanksgiving

(f) The labels of sausages encased in natural casings made from meat or poultry viscera shall identify the type of meat or poultry from which the casings were derived, if the casings are from a different type of meat or poultry than the encased meat or poultry. The identity of the casing, if required, may be placed on the principal display panel or in the ingredient statement. Establishments producing, manufacturing, or using natural sausage casings are to maintain records documenting the meat or poultry source in accordance withsubpart Q of this part.

https://www.law.corn.../text/9/381.117

1. CFR › Title 9 › Chapter III › Subchapter A › Part 381 › Subpart N › Section 381.117