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Do we need USDA to be involved for the permit if we use collagen in snack products?

collagen

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#1 Gracezy

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Posted 03 August 2020 - 10:17 PM

Dear IFSQN team,

 

 

I understand that Bovin collagen is made from cow ( Animal by products). Do we need USDA to be involved for the permit if we use it in Snack products.

 

Will the allergen will be fish ir its derivatives if we use marine collagen?

 

Thank you in advance!



#2 dstout

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Posted 04 August 2020 - 12:41 AM

Yes, your ingredient statement would have to declare bovine collagen and/or fish collagen in the order of amount used (so the nutrition panel states it contains the appropriate collagen). The fish product would have to have the typical Contains: Fish (Collagen) or some similar statement.

 

Hope this helps!

Dan



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#3 Gracezy

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Posted 04 August 2020 - 02:43 PM

Thank you Dan! 

Yes, your ingredient statement would have to declare bovine collagen and/or fish collagen in the order of amount used (so the nutrition panel states it contains the appropriate collagen). The fish product would have to have the typical Contains: Fish (Collagen) or some similar statement.

 

Hope this helps!

Dan



#4 Ryan M.

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Posted 04 August 2020 - 05:40 PM

Well, technically you are not required to identify the source of the collagen in your ingredient panel.  You can simply state "collagen" as part of the ingredient statement / declaration.

 

If you are using a fish based collagen check with your supplier, or potential supplier, to confirm allergen status.  If it contains fish allergen then you need to identify the allergen on the labeling as required either by "collagen (fish)" or "Contains: fish".

 

USDA does not need to be involved in this as it falls under FDA regulations.  FDA does not require you to submit labels for their approval before using.  They leave this up to the manufacturer, but do inspect labeling when conducting facility inspections.



#5 Gracezy

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Posted 04 August 2020 - 06:07 PM

Hi Ryan, This is amazing. I've done some reaseach and informed by boss this morning. Now that I see your advice, I feel so much better and more confident for pursuing this project on the right direction. You're the star! Thank you!

 

 

Well, technically you are not required to identify the source of the collagen in your ingredient panel.  You can simply state "collagen" as part of the ingredient statement / declaration.

 

If you are using a fish based collagen check with your supplier, or potential supplier, to confirm allergen status.  If it contains fish allergen then you need to identify the allergen on the labeling as required either by "collagen (fish)" or "Contains: fish".

 

USDA does not need to be involved in this as it falls under FDA regulations.  FDA does not require you to submit labels for their approval before using.  They leave this up to the manufacturer, but do inspect labeling when conducting facility inspections.



#6 Ryan M.

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Posted 04 August 2020 - 07:49 PM

Welcome, one point to clarify though that I should have asked, but are any of the other ingredients require oversight by USDA?  Specifically, any meat ingredients, or is this a meat snack?  If it is, then yes the USDA is involved and must approve the label before you use.

 

The only other caveat is a dairy / milk based item which is FDA oversight, and the label and product must be approved by the state and local inspector before use.  

 

I didn't want to assume that either of these did not apply.

 

Hi Ryan, This is amazing. I've done some reaseach and informed by boss this morning. Now that I see your advice, I feel so much better and more confident for pursuing this project on the right direction. You're the star! Thank you!



#7 billbrochin

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Posted 05 August 2020 - 07:21 PM

If the meat total is above 2% then the USDA would need to be involved.  Otherwise FDA only.  You will need to have your collagen supplier verify that the material is sourced from BSE free cattle and maintain that record in the event the FDA asks for it.



#8 Gracezy

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Posted 05 August 2020 - 08:42 PM

Hi Ryan, Sorry for the delay. I just finished my SQF audit. 
 

Yup, we only produce nuts and rice snacks and no any meat in our facility. Thank you again for pointing it out. You're the best!

 

Just for my curiosiry, besides meats category, what else that USDA need to be involve or come for the inspection.

For my understanding is that they need to come to issue  the certificates whenever we import or export agricultural products. eg. rice that the phytosanitary needs to be issued by USDA inspector. ( We do not import or export any of those). 

 

 

Welcome, one point to clarify though that I should have asked, but are any of the other ingredients require oversight by USDA?  Specifically, any meat ingredients, or is this a meat snack?  If it is, then yes the USDA is involved and must approve the label before you use.

 

The only other caveat is a dairy / milk based item which is FDA oversight, and the label and product must be approved by the state and local inspector before use.  

 

I didn't want to assume that either of these did not apply.



#9 Gracezy

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Posted 05 August 2020 - 09:31 PM

Hi Billbrochin,

 

Thank you so much! This is very good infomation. I'll note it down for my project. I really appreciateit your help. 

If the meat total is above 2% then the USDA would need to be involved.  Otherwise FDA only.  You will need to have your collagen supplier verify that the material is sourced from BSE free cattle and maintain that record in the event the FDA asks for it.



#10 Ryan M.

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Posted 06 August 2020 - 12:21 PM

Good call out Bill on the BSE.

 

If the meat total is above 2% then the USDA would need to be involved.  Otherwise FDA only.  You will need to have your collagen supplier verify that the material is sourced from BSE free cattle and maintain that record in the event the FDA asks for it.

 

For inspections I can't think of any where the USDA would be involved, even if you export your goods from the US; that still falls under the FDA.  The USDA does provide documentation and certification for export of some goods like milk based products.

 

Hi Ryan, Sorry for the delay. I just finished my SQF audit. 
 

Yup, we only produce nuts and rice snacks and no any meat in our facility. Thank you again for pointing it out. You're the best!

 

Just for my curiosiry, besides meats category, what else that USDA need to be involve or come for the inspection.

For my understanding is that they need to come to issue  the certificates whenever we import or export agricultural products. eg. rice that the phytosanitary needs to be issued by USDA inspector. ( We do not import or export any of those). 

 







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