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#1 Rich14

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Posted 25 February 2020 - 02:15 PM

Does anyone have a link or specific information about what is required of one business selling a product to another business for further processing in their own application in terms of ingredient declarations and nutritional labeling? 

 

Everything I can find lends itself to retail labeling which we have squared away.  I cannot find if the rules are the same or different.  Any help or guidance would be appreciated!

 

Thanks

Rich



#2 LesleySR

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Posted 25 February 2020 - 02:45 PM

Hi Rich14

 

I’m not sure about USA but in UK our food labelling legislation relates to products offered for retail sale.

 

I work for an ingredient supplier with factories in Europe/US/China & the way we approach this is to sell our products according to a formal specification which is signed by both parties & carries all the allergen data/pack size & pallet configuration/chemical parameters/microbiological parameters/nutritional data/shelf life/MLOR (minimum life on receipt).  The contracts (for purchase of raw materials & sale of finished products) are set up by purchasing/sales according to standard terms & conditions & refer to the relevant specification number (ingredient or finished product).  The US factory works in this way too, so I am assuming this must be relevant & compliant with US regulations.

 

I have worked for many B2B ingredient suppliers & this is the way everybody has managed the specifics of labeling & nutritional advice as long as I can remember, unless the customer has a different way of managing the process (they often have on-line specification systems or require bags to be labelled if they contain allergens) this seems like the standard way of managing the specifics?.

 

One thing we don’t do – and I am very firm on this - is to offer our customers advice on how they should label or market  their products – this is because they own their brand (we don't), labeling legislation varies according to country of sale, and it can & does change frequently.  Therefore,  it is entirely the responsibility of the party who is using the ingredients to make a finished product as to how their product is labeled….. ultimately we are an ingredient manufacturer, not a global food labeling consultancy.



#3 QAGB

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Posted 25 February 2020 - 03:04 PM

Hi Rich14,

 

My understanding is that you're required to list statement of identity, name and address of manufacturer/packer/distributor, statement of ingredients, and net quantity of contents as the minimum information. If your product meets exemption requirements, you are not required to have a nutritional panel on the labeling.

 

https://www.ecfr.gov...101_main_02.tpl



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#4 Rich14

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Posted 25 February 2020 - 03:04 PM

Thanks Lesley.

 

In your experience, the ingredient declaration is full and complete within another document?  For instance a spec sheet?  And not indicated on the product label?



#5 LesleySR

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Posted 25 February 2020 - 03:25 PM

Thanks Lesley.

 

In your experience, the ingredient declaration is full and complete within another document?  For instance a spec sheet?  And not indicated on the product label?

Hi Rich14

 

Yes, this is correct - most of what we sell is commodities (ie. a single ingredient) but where there is more than one ingredient in a finished product, this will be captured on the specification, along with complete nutritional information.

 

The box/bag label will show the part number eg. M460, company name, company address, weight declaration, date of manufacture, date of expiry, storage information, shelf life after opening pack, details of allergens (if any within the product).

 

Where the material consists of more than one ingredient we would not necessarily provide a full ingredient breakdown on the pack label as this information is all contained on the formal specification (BRC V8 section 3.6 states the requirements for specification management - if you can obtain a copy - this is copyright so I cannot attach a copy here).

 

Sometimes customers do have specific label requests - although this is usually for a bespoke item which will have a customer specific part number.



#6 QAGB

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Posted 25 February 2020 - 05:54 PM

Still a bit fuzzy to me. I've always worked by FDA regulations, and as far as I can tell, an ingredient statement is required to be on a label based on 21 CFR Part 101.4 and the Federal FD&C Act. I know there are certain exemptions as to what ingredients have to be declared (processing aids), and I imagine if you are working with a single ingredient, you wouldn't necessarily need an ingredient statement if it's already listed prominently on the principal display. For everything we produced in a package form with two or more ingredients though, there was some sort of ingredient statement. 



#7 Fishlady

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Posted 01 March 2020 - 07:48 PM

The rules are a bit fuzzy for B2B, but I have always included product identity, all ingredients, net weight, manufacturer’s name and address at the least, plus whatever other information is requested by the customer.



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