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Ingredient Labeling Details

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Posted 01 April 2020 - 03:50 PM

We're working to reduce our ingredient decks by incorporating sub-ingredients into our deck instead of listing them parenthetically and I am overwhelmed. I was planning to attend a seminar but those have all been significantly delayed due to current world events and management would understandably like to keep things moving forward.


A few questions I have encountered:


  1. Has anyone taken a labeling course/webinar or have a labeling book that they recommend that discusses ingredient labeling in more depth?
    1. The CFR only provides so much direction and most classes I have found only go over the basics of ingredient labeling ie list in order of dominance, allergens, etc.
  2. Can I combine Non-Fat Dry Milk with Powdered Milk or do they need to be listed separately?
  3. Do I need to list Cocoa and Cocoa processed with alkali or can I only put Cocoa processed with alkali?
  4. Any additional direction on incidental additives and how to know what you can legally remove from the label - is there a % it has to be less than or is it simply if they have "no technical or functional effect"?
  5. Flavor labeling when the flavor is the characterizing flavor - ie a Cookies and Cream flavored item, the Cookies and Cream Flavor has to be listed in the ingredient deck but do the sub ingredients of that flavor then have to be listed?


Thanks for any direction anyone can provide! 

Edited by kzim, 01 April 2020 - 03:51 PM.

The Food Scientist

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Posted 01 April 2020 - 06:31 PM

Have you checked the FDA Labeling guide? It has a lot of useful info to guide you on labeling:




Also, in some cases I had to directly call the FDA if there were answers I could not find. They were always happy to help.



Edited by The Food Scientist, 01 April 2020 - 06:33 PM.

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


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Posted 09 April 2020 - 02:31 PM



I just answer from the EU perspective: a list of ingredient should contain each ingredient used and as long as two ingredients are different they have to be listed separately: cream or cream powder, butter or butter fat, fruit juce and fruit juice concentrate  are not the same. Avoid anything what can misslead the consumer.  In the EU you may use QUID  (quantitaive ingredient declaration) what makes it more critical.




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