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Using old packaging stocks and the current FDA Packaging regulations


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minighi

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Posted 08 October 2020 - 02:53 PM

Hello,

 

Currently we have some packaging that we are working through that meets 2019 FDA Packaging regulations. I know that there have been some updates to the 2020 regulations which we have addressed in our new packaging.  

 

The question I have is this...we have a product that is RTE wrapped in the 2019 packaging but the bulk packaging is the 2020 packaging with the required changes. could this present a problem with FDA? 

 

our justification for this is that we are not intentionally printing old packaging but just working through we currently have on hand. and will make the necessary changes when we re order.

 

any information with regulatory evidence would be much appreciated. 

 

 

THANKS!



kfromNE

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Posted 08 October 2020 - 03:20 PM

Hello,

 

Currently we have some packaging that we are working through that meets 2019 FDA Packaging regulations. I know that there have been some updates to the 2020 regulations which we have addressed in our new packaging.  

 

The question I have is this...we have a product that is RTE wrapped in the 2019 packaging but the bulk packaging is the 2020 packaging with the required changes. could this present a problem with FDA? 

 

our justification for this is that we are not intentionally printing old packaging but just working through we currently have on hand. and will make the necessary changes when we re order.

 

any information with regulatory evidence would be much appreciated. 

 

 

THANKS!

If you're talking about labels on the packaging - no this is not allowed. However I do believe they extended the time for small businesses to be in compliance.

 

https://www.fda.gov/...ion-facts-label

 

https://www.fda.gov/...ion-facts-label

 

When will I start to see the new label?

Many manufacturers are already using the new label, but they have more time to make the changes. Changes must be made by January 1, 2020, for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food sales have an extra year to comply – until January 1, 2021. Manufacturers of most single-ingredient sugars such as honey and maple syrup and certain cranberry products have until July 1, 2021 to make the changes. Manufacturers of certain flavored dried cranberries have until July 1, 2020 to make the changes.

 

14. How much time will manufacturers have to make these changes?

The FDA extended the compliance dates for the Nutrition Facts and Supplement Facts label final rule and the Serving Size final rule, from July 26, 2018 to January 1, 2020, for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food sales would receive an extra year to comply – until January 1, 2021. Manufacturers of single-ingredient sugars such as honey and maple syrup and certain cranberry products have until July 1, 2021 to make the changes.



minighi

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Posted 08 October 2020 - 03:32 PM

if you average less than 10 million is sales you are allotted an additional 1.5 yrs, if not all packaging must comply with the 2020 packaging update by January 2021? corrent?

 

so you couldn't have a bulk packaging that meets the 2020 regulation with the individual packaging be 2019?



Ryan M.

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Posted 15 October 2020 - 01:14 PM

 

The FDA extended the compliance dates for the Nutrition Facts and Supplement Facts label final rule and the Serving Size final rule, from July 26, 2018 to January 1, 2020, for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food sales would receive an extra year to comply – until January 1, 2021. Manufacturers of most single-ingredient sugars such as honey and maple syrup and certain cranberry products have until July 1, 2021, to make the changes. Manufacturers of certain flavored dried cranberries have until July 1, 2020 to make the changes.

In May 2016, the U.S. Food and Drug Administration finalized the Nutrition Facts and Supplement Facts Label and Serving Size final rules and set the compliance date for July 26, 2018, with an additional year to comply for manufacturers with annual food sales of less than $10 million. After those rules were finalized, industry and consumer groups provided the FDA with feedback regarding the compliance dates. After careful consideration, the FDA determined that additional time would provide manufacturers covered by the rule with necessary guidance from FDA, and would help them be able to complete and print updated nutrition facts panels for their products before they are expected to be in compliance.

 

 

 

 

If you have less than $10 million in sales you can continue to work through your old labeling.  If you have new and old labeling mixed it should not pose an issue.  This is to be expected to some degree.


Edited by Ryan M., 15 October 2020 - 01:14 PM.





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