Jump to content

  • Quick Navigation
Photo
- - - - -

Label when two slightly different ingredients from two suplliers


  • You cannot start a new topic
  • Please log in to reply
8 replies to this topic

#1 NEDA

NEDA

    Grade - AIFSQN

  • IFSQN Associate
  • 26 posts
  • 2 thanks
0
Neutral

  • United States
    United States
  • Gender:Female

Posted 28 November 2019 - 08:51 PM

Hello everyone,

 

I would like to know for sub ingredient declaration on the label of the product that has dried fruit as an ingredient if we have 2 different suppliers

 

- supplier 1 : ingredient: raisin (no sub ingredient)

- supplier 2 : ingredient: raisin ( with a few sub-ingredients)

 

depending on the supplier inventory we get the raisin from suppliers 1 or 2.

 

to prevent changing our artwork all the time, could we declare on the label raisin with sub-ingredients but use some times raisin without sub ingredient? 

 

I would appreciate your help.

 



#2 QAGB

QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 667 posts
  • 250 thanks
104
Excellent

  • Earth
    Earth

Posted 02 December 2019 - 03:09 PM

I would say no; you would need two separate labels (one for each raisin type). You cannot declare on the label ingredients that are not in your product. If you're using raisins from supplier 1, you can't declare sub-ingredients that aren't in the product. Alternatively, you could buy some of these sub-ingredients in supplier 2's raisins and add small amounts to your batches with supplier 1 raisins. That way you have consistent ingredients in both.



Thanked by 1 Member:

#3 NEDA

NEDA

    Grade - AIFSQN

  • IFSQN Associate
  • 26 posts
  • 2 thanks
0
Neutral

  • United States
    United States
  • Gender:Female

Posted 02 December 2019 - 08:10 PM

Thank you. My point is this is a sub-ingredient declaration. we might get raisin from supplier 1 or 2. would you mean for one product should we have two different package because of raisin sub-ingredients? Does over declaring a sub-ingredient consider misleading or not?



#4 QAGB

QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 667 posts
  • 250 thanks
104
Excellent

  • Earth
    Earth

Posted 02 December 2019 - 08:27 PM

Thank you. My point is this is a sub-ingredient declaration. we might get raisin from supplier 1 or 2. would you mean for one product should we have two different package because of raisin sub-ingredients? Does over declaring a sub-ingredient consider misleading or not?

 

 

I think I am understanding your question, and I don't think it matters that this is a sub-ingredient declaration. If you don't intend on revising your formula a bit to accommodate both suppliers, then yes - you should have two different labels for your products depending on which raisin supplier you use. If I recall correctly, over-declaring any ingredient (sub or not) would be considered misleading.



#5 QAGB

QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 667 posts
  • 250 thanks
104
Excellent

  • Earth
    Earth

Posted 02 December 2019 - 08:49 PM

It looks as though you have posted a new forum question on the same topic. I do realize you have categorized that one as CFIA rather than FDA. I will keep my responses in this thread. See link.

 

https://www.ifsqn.co...specifications/



#6 Simon

Simon

    IFSQN...it's My Life

  • IFSQN Admin
  • 12,337 posts
  • 1296 thanks
604
Excellent

  • United Kingdom
    United Kingdom
  • Gender:Male
  • Location:Manchester
  • Interests:Married to Michelle, Father of three boys (Oliver, Jacob and Louis). I enjoy cycling, walking and travelling, watching sport, especially football and Manchester United. Oh and I love food and beer and wine.

Posted 02 December 2019 - 08:49 PM

Neda, please do not create new topics on the same subject; instead continue the discussion here.

I've deleted the duplicate.

 

Regards,

Simon


hand-pointing-down.gif
 
Get FREE bitesize education with IFSQN webinar recordings.
 
Download this handy excel for desktop access to over 140 Food Safety Friday's webinar recordings.
https://www.ifsqn.com/fsf/Free%20Food%20Safety%20Videos.xlsx

 
Check out IFSQN’s extensive library of FREE food safety videos
https://www.ifsqn.com/food_safety_videos.html

 

recommend-us-on-facebook.png


#7 NEDA

NEDA

    Grade - AIFSQN

  • IFSQN Associate
  • 26 posts
  • 2 thanks
0
Neutral

  • United States
    United States
  • Gender:Female

Posted 03 December 2019 - 01:06 PM

Neda, please do not create new topics on the same subject; instead continue the discussion here.

I've deleted the duplicate.

 

Regards,

Simon

OK Simon



#8 FurFarmandFork

FurFarmandFork

    Food Safety Consultant, Production Supervisor

  • IFSQN Fellow
  • 1,264 posts
  • 577 thanks
170
Excellent

  • United States
    United States
  • Gender:Male
  • Location:Oregon, USA

Posted 03 December 2019 - 06:58 PM

Thank you. My point is this is a sub-ingredient declaration. we might get raisin from supplier 1 or 2. would you mean for one product should we have two different package because of raisin sub-ingredients? Does over declaring a sub-ingredient consider misleading or not?

Depends on the ingredient. Over-declaration is an issue if it's a value added things (e.g. an organic ingredient, or something consumers look for), but if it isn't value added (e.g. one of your raisin formulas contains an incidental amount of salt, and there is already salt elsewhere in the product) then it may be appropriate.

 

Unfamiliar with how CFIA is going to be about that, but over here if it makes your product look worse, no one is going to care that much. FDA cares much more about consumer's being ripped off and under-declaration than they do about label accuracy in general.


Austin Bouck
Owner/Consultant at Fur, Farm, and Fork.
Consulting for companies needing effective, lean food safety systems and solutions.

Subscribe to the blog at furfarmandfork.com for food safety research, insights, and analysis.

Thanked by 1 Member:

#9 QAGB

QAGB

    Grade - PIFSQN

  • IFSQN Principal
  • 667 posts
  • 250 thanks
104
Excellent

  • Earth
    Earth

Posted 03 December 2019 - 07:37 PM

Depends on the ingredient. Over-declaration is an issue if it's a value added things (e.g. an organic ingredient, or something consumers look for), but if it isn't value added (e.g. one of your raisin formulas contains an incidental amount of salt, and there is already salt elsewhere in the product) then it may be appropriate.

 

Unfamiliar with how CFIA is going to be about that, but over here if it makes your product look worse, no one is going to care that much. FDA cares much more about consumer's being ripped off and under-declaration than they do about label accuracy in general.

 

Good point on salt being listed twice (once as incidental and once as an ingredient elsewhere). This is probably ok, but as a rule of thumb not sure I would want to justify my label approach based on how much the FDA (or CFIA in this case) cares about certain standards. It should be relatively easy to add "incidental amounts" of ingredients to a formulation so that all labels can be equal regardless of different suppliers' incidental ingredients.


Edited by QAGB, 03 December 2019 - 07:38 PM.


Thanked by 1 Member:



0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users