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Ingredients that need to be broken down in sub ingredients

Label compliance labels FDA label compliance

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#1 Brelimo70

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Posted 13 May 2019 - 05:10 PM

Hi to all label experts: Im wrecking by brains here trying to figure this one out, we are  small company that produces frosted/non frosted cookies and baking goods (brownies-cornbread) the owner of the company just pointed out that labels seem to be to long in the section of the declaration of ingredients, he is trying to push for a reduction of content, right now we are declaring all of the ingredients and the ingredients that they are made of, now the question is do we have to do this for all of the ingredients even if they are a small portion of the content? what about colors, flavorings and decorates (sprinkles) ? what if we already declare ingredient like sugar, do we have to declare it in each ingredient that it does contain it? 

 

Can someone point me to the section of the FDA code that handles this type of issues?

 

Thanks for all of the help.

 

Brenda. 



#2 lmacfarland

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Posted 13 May 2019 - 05:20 PM

I am not entirely familiar with the requirements in US but Canada has updates the requirements and allows like ingredients to be listed together. This was introduced with the new nutritional label requirements

 

I was able to find this, not sure if it will help you find your answer but hopefully helps some 

https://www.foodpack...glabels.net.pdf  



#3 FoodSafetyPlanet

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Posted 13 May 2019 - 05:57 PM

Hi Bre,

Check out the FDA’s small business labeling exemptions since you mentioned you are one. I can’t recall that it addresses ing breakouts specifically, but it doesn’t hurt to check.

Edit: Disregard, this is what you need. Source.

 

(i) By declaring the established common or usual name of the ingredient followed by a parenthetical listing of all ingredients contained therein in descending order of predominance except that, if the ingredient is a food subject to a definition and standard of identity established in subchapter B of this chapter that has specific labeling provisions for optional ingredients, optional ingredients may be declared within the parenthetical listing in accordance with those provisions.


Edited by FoodSafetyPlanet, 13 May 2019 - 06:08 PM.


#4 KfromIA

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Posted 13 May 2019 - 06:32 PM

Hi to all label experts: Im wrecking by brains here trying to figure this one out, we are  small company that produces frosted/non frosted cookies and baking goods (brownies-cornbread) the owner of the company just pointed out that labels seem to be to long in the section of the declaration of ingredients, he is trying to push for a reduction of content, right now we are declaring all of the ingredients and the ingredients that they are made of, now the question is do we have to do this for all of the ingredients even if they are a small portion of the content? what about colors, flavorings and decorates (sprinkles) ? what if we already declare ingredient like sugar, do we have to declare it in each ingredient that it does contain it? You only have to declare sugar once on the label. However; when deciding on the order of the ingredients, you must take in consideration all of the sugar used in your ingredients. For example if you use 1lb white flour, 0.8lb white sugar and the sprinkles contain 0.3lb sugar. Now if the sprinkles weren't used, flour would go first on the ingredient list however with the addition of sprinkles, the amount of sugar in the recipe increased. Now sugar would go before flour on the ingredient list.

 

Can someone point me to the section of the FDA code that handles this type of issues?

 

Thanks for all of the help.

 

Brenda. 

https://www.fda.gov/...-labeling-guide

 

Page 17. - Category 6: Ingredients

 

FoodSafetyPlanet mentioned small business exemptions - not sure about this.



#5 Brelimo70

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Posted 13 May 2019 - 06:51 PM

Thank you all very much, i did fin the section that food safety planet pointed out, and i think it should be sufficient to get the owner on board for the sake of compliance ( even if still he considers the label to be to busy) thank you so much for the support, and please if you have any further information keep sharing it here, i think this topic is very important and there only very little information available. 

 

Brenda.



#6 cindyhaz

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Posted 15 May 2019 - 09:06 PM

Anyone responsible for labeling should become familiar with 21CFR101

 

101.4 is a general guide.  https://www.accessda...ch.cfm?fr=101.4

101.22 addresses spices, flavors, colors, and preservatives.

 

It's not easy reading, but it's important. Too many foods are recalled for labeling issues, especially undeclared allergens, so it's wise  to be accurate.



#7 majoy

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Posted 27 May 2019 - 06:21 PM

Thank you all very much, i did fin the section that food safety planet pointed out, and i think it should be sufficient to get the owner on board for the sake of compliance ( even if still he considers the label to be to busy) thank you so much for the support, and please if you have any further information keep sharing it here, i think this topic is very important and there only very little information available. 

 

Brenda.

 

Yeah, this is an issue, regulatory vs. marketing/graphic artist/owner etc perspective on what should be included or lay out and contents of the label. We get it, they want the label to be pretty, colorful and catchy for consumers, but regulatory is regulatory..


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