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Label when two slightly different ingredients from two suplliers


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#1 NEDA

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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

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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.



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#3 NEDA

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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

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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

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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

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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.

 

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Simon


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#7 NEDA

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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

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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.


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#9 QAGB

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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.


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