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carolyncmj

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Posted 07 November 2019 - 07:55 PM

We are changing the ingredients which will cause the nutritional panel to change on some of our food labels, there is no allergen change.

My question is does the FDA require the recipe name to change on the label?

If so where is the rule listed in the FDA?

If not is there a FDA statement for it?


Edited by carolyncmj, 07 November 2019 - 07:56 PM.


The Food Scientist

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Posted 07 November 2019 - 08:14 PM

Everything you need to know about labeling is right here:

 

https://www.fda.gov/.../81606/download


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


The Food Scientist

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Posted 07 November 2019 - 08:17 PM

Also not sure what you mean by recipe name change. I am assuming your product is the same but you changed up your recipe a bit, correct?


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


carolyncmj

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Posted 07 November 2019 - 08:20 PM

Also not sure what you mean by recipe name change. I am assuming your product is the same but you changed up your recipe a bit, correct?

Yes that is correct,I can't find nothing in the FDA label guidelines that state we have to update the recipe name on the label.



carolyncmj

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Posted 07 November 2019 - 08:21 PM

Everything you need to know about labeling is right here:

 

https://www.fda.gov/.../81606/download

 

Everything you need to know about labeling is right here:

 

https://www.fda.gov/.../81606/download

There is nothing about ingredient and nutritional panel change. with relations to recipe label name



The Food Scientist

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Posted 07 November 2019 - 08:27 PM

Can you perhaps share with me what the product is? A little more detail about whats changing?

 

Now my previous experience in labeling, if its the same product, with just change in ingredients, just put the new ingredients on their with new nutritional label. Of course keep records of the previous recipe! I used to use a software called Genesis R&D and would change recipe names based on whats new and old for record keeping purposes. 


Everything in food is science. The only subjective part is when you eat it. - Alton Brown.


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Ryan M.

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Posted 07 November 2019 - 09:21 PM

The product name on the label must identify what is in the package.  If your product has a standard of identity then the product name on the label must conform to the standard of identity, as well as, the ingredients used.  If your product does not have a standard of identity you have some leeway on the product name on the label.

 

A recipe change does not necessitate a label change, unless you have significantly altered the main ingredients used.  For example, "Potato Chips" and you started including other types of main ingredients like yam, or onions.  You would need to modify the product name.  But, if your "Potato Chips" seasoning has changed you do not need to update the name, just the ingredients, nutritional (if affected), and allergen info (if affected).



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Fishlady

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Posted 15 November 2019 - 05:32 AM

For US laws, the ingredients must be listed in descending order of predominance. If your recipe has changed the amounts of the ingredients, then you will need to change your ingredient statement in your label accordingly.



Psych6

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Posted 09 December 2019 - 03:24 AM

We are changing the ingredients which will cause the nutritional panel to change on some of our food labels, there is no allergen change.

My question is does the FDA require the recipe name to change on the label?

If so where is the rule listed in the FDA?

If not is there a FDA statement for it?

If the name in front panel remains suitable for the product, you don't need to change it

 

About nutritional panel, well maybe you'll need to change it

Ingredients: It must be listed in descendant order of predominance, unless those after a statement "Contains 2% or less of .....", if you put that statement



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