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Is it OK to exclude net weight from labels for a hotel product?


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#1 larissaj

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Posted 15 January 2020 - 06:51 PM

Hello,

 

We have a customer who wants us to package product for her in 2oz bags with her label. She does not want the net weight on the label. The product will be for a hotel from what we know. Is this ok? We are to print all the nutrtionals and allergens however the front label is all colorful and she is putting the name of the product on the front and thats it. 



#2 AC2018

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Posted 15 January 2020 - 06:56 PM

I believe if it is not intended for retail sale it falls under a list of exemptions according to the CFR. I would have to dig to find the exact clause but I had something similar come up in the past with packaging small packs of nuts for an airline. 



#3 larissaj

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Posted 15 January 2020 - 06:58 PM

I have been searching and have had a hard time. we dont know if its for resale exactly since we dont know the whole story of the project. 



#4 AC2018

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Posted 15 January 2020 - 07:10 PM

Sounds oddly familiar to me! This is really the only exemption I could find right off the bat, it's been awhile since I've dealt with label regulations since I now work for a co-packer so all of this stuff is done for us now! 

 

(3) Individual serving-size packages of foods containing less than 1/2 ounce or less than 1/2 fluid ounce for use in restaurants, institutions, and passenger carriers, and not intended for sale at retail, shall be exempt from the required declaration of net quantity of contents specified in this part.

 

I would try to ask the customer why the net weight can not be included and explain that according to label regulations by the FDA, anything over 1/2 ounce needs to declare net weight. Then from there determine if you still want to package their product. 



#5 FurFarmandFork

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Posted 20 January 2020 - 11:42 PM

Real easy, if it's being sold retail everything pretty much has to be on there.

 

If  a customer does not want to include required components on the label, don't put your name on it. Instead use "distributed by" and the customer's contact information.

 

At the end of the day, only fight as much as your company cares about the customer. If it's not sold in California, almost nobody is ever enforcing labeling in the US.


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

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