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US label requirements for ingredients

US ingredients regulations

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#1 SpiceyQA

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Posted 30 October 2019 - 11:55 AM

The company I work for produces a spice mix for a restaurant to serve. On our label we currently list all ingredients that we use. 

My question is do I have to list the ingredients of components that make up the components that we use?



#2 kfromNE

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Posted 30 October 2019 - 12:03 PM

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



#3 SpiceyQA

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Posted 30 October 2019 - 01:31 PM

ok kinda helpful. Does this cover non consumer products as well?



#4 kfromNE

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Posted 30 October 2019 - 02:31 PM

This does cover non-consumer products as well. Some of the spices can be considered a trade secret on your part and be labeled as spices - as long as they aren't an allergen. But in general with any product the sub-ingredients need to be on the label.



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#5 SpiceyQA

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Posted 30 October 2019 - 02:43 PM

This does cover non-consumer products as well. Some of the spices can be considered a trade secret on your part and be labeled as spices - as long as they aren't an allergen. But in general with any product the sub-ingredients need to be on the label.

Do you have a source for this? I'm gearing up for a fight with production.



#6 Njaquino

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Posted 30 October 2019 - 04:08 PM

Great question I have been wondering myself. I work for a seasoning company and I have always been asked. I have them list all the spices, since on the FDA label guide it makes a comment about spices. 

 

"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)" P 18 of the guidance.



#7 Hank Major

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Posted 30 October 2019 - 07:03 PM

The FDA lists exactly what they consider spices:

 

Allspice, Anise, Basil, Bay leaves, Caraway seed, Cardamon, Celery seed, Chervil, Cinnamon, Cloves, Coriander, Cumin seed, Dill seed, Fennel seed, Fenugreek, Ginger, Horseradish, Mace, Marjoram, Mustard flour, Nutmeg, Oregano, Paprika, Parsley, Pepper, black; Pepper, white; Pepper, red; Rosemary, Saffron, Sage, Savory, Star aniseed, Tarragon, Thyme, Turmeric.

 

21CFR101.22(a)(2)

 

But keep in mind that certain ingredients are considered colorants by the FDA, for example annatto, and must be listed.  Also, vegetables ("traditionally regarded as foods") such as onion, garlic, and celery (leaf) must be listed.  Lemon peel, tomato powder, and so forth are also not spices.

 

In practice, retailers tend to err on the side of caution, usually listing celery seed, ginger, horseradish, mustard, paprika, parsley, red pepper, and turmeric.  Finally, you will often see black pepper listed. I believe that this is because retailers think consumers might otherwise wonder what the black specks are.



#8 SpiceyQA

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Posted 30 October 2019 - 07:48 PM

Great question I have been wondering myself. I work for a seasoning company and I have always been asked. I have them list all the spices, since on the FDA label guide it makes a comment about spices. 

 

"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)" P 18 of the guidance.

So what I'm getting from you here is that the recipes with 20 ingredients with most of those spices, needs to be spelled out? Isn't that a trade secret for spice blends?



#9 Hank Major

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Posted 30 October 2019 - 08:21 PM

So what I'm getting from you here is that the recipes with 20 ingredients with most of those spices, needs to be spelled out? Isn't that a trade secret for spice blends?

 

No, there is no such requirement. Just look at the ingredient lists of blends sold by the big spice companies such as McCormick. They routinely just list 'spices'.







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