USDA inspection legend requirements for Multi-Pack Beef Sticks

Dealing with an inexperienced USDA inspector, we make a beef stick product that is sold in a multi pack display made for individual sales at the cash register, individual beef sticks have nutritionals and USDA bug on them, Inspector wants the box that holds the beef sticks with the USDA inspection legend as well.

Thoughts?

It doesn't need the legend for consumer facing labeling since it's on each individual beef stick, however if you're using the display box as a shipping container, then the mark of inspection needs to be on it, your inspector would be correct.

https://askfsis.cust...kVreEl3JTIxJTIx

What are the markings required on a shipping container?

An official inspection legend (including establishment number) and a handling statement (if product inside is perishable) are required on all shipping containers filled with immediate containers. Refer to 9 CFR 316.13 or 381.127.

Further, if retail sale products are random weight and shipped without their net weight statements, the shipping container is also required to bear a net weight statement per 9 CFR 317.2(h) (9) (i) or 381.121(a). Further, the poultry shipping containers need to bear the following statements: "Tare weight of consumer package ___ oz." weighed to nearest 1/8 ounce or less and "Net wt. to be marked on consumer packages prior to display and sale."

Any other information is optional but must be truthful and not misleading.

Refer to 9 CFR 301.2 or 381.1 for the definitions of "immediate container" and "shipping container."

 

Thank you for the clarification everyone, it is what I thought, the caddie being used (displayed at Point of Purchase) is not the shipping container, we pack 6 caddies in every master case (shipping container) stores then display the caddie with the individual items -  individual items all have compliance to the labeling rules including the USDA legend.

Sorry just had to butt in here, i think your inspector is thinking about retail ready packaging (RRPs). This is the trend now for many retail stores, a retail ready packaging (RRP) used as shipping container and display containers, reduces work for people stacking the shelves and less waste for packaging sustainability initiatives.

thank you for the feedback everyone, just to be clear no it is not rrp, the beef sticks are placed in caddies, then 6 caddies go into a master case, the individual beef sticks meet all labeling requirements, Inspector asked the policy office and they agreed that the caddies do not need the Legend.