Labeling sub ingredients
Hello,
So we have a wasabi pea that we use by itself and also add to mixes. For the label, it says wasabi flavoring and some companies don't like all thats in there. Is it ok to state wasabi flavoring and not have the sub ingredients? No allergens in the sub ingredients when found some companies breakdowns.
Short answer - you need to label the sub ingredients. Long answer: The sub ingredients of a food that is an ingredient in another food may be declared parenthetically following the name of the ingredient or may be declared by dispersing each ingredient in its order of predominance in the ingredient statement without naming the original ingredient. 21 CFR 101.4(b)(2)
How are spices, natural flavors or artificial flavors declared in ingredient lists?
Answer: These may be declared in ingredient lists by using either specific common or usual names or by using the declarations “spices,” “flavor” or “natural flavor,” or “artificial flavor.”
“INGREDIENTS: Apple Slices, Water, Cane Syrup, Corn Syrup, Modified Corn Starch, Spices, Salt, Natural Flavor and Artificial Flavor”
However, products that are spices or spice blends, flavors or colors must list each ingredient by name. FD&C Act 403(i)(2) and 21 CFR 101.22(h)(1)
are you selling to just retail or is it going to wholesale also?