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hannahharo

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Posted 21 January 2021 - 02:13 PM

Hello! I have some questions about the Nutrition Facts Label and how to format. We are manufacturing an energy powder mix and packaging in a cylinder tub. Our marketing team came up with the following label. Could someone look over this and suggest any edits or corrections? Does this label need to have the same font throughout? I know the font SIZE varies but I am not sure if we must use the exact font throughout the label? I am also wondering if the label can be slanted like this? The marketing team referenced the red bull nutrition label that is also slanted, however, I don't see anything on the FDA label guidance document that says this is allowed? Last question- can the background be red? I have only seen black and white nutrition labels so i am not sure about this one either. Any help would be appreciated! Thank you!

 

 

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Scampi

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Posted 21 January 2021 - 02:37 PM

From what I can glean, that panel is not allowed

 

These are the allowed formats..........https://www.fda.gov/.../99203/download

 

I've never seen anything other than a black and white panel  seems like an easy issue to avoid by leaving it black and white

 

Also, I did a quick google search for red bull panel images in the last year-----the vast majority were straight, not angled, so push back on the marketing team to ask what cans/ for what market, they are referring too

 

This link tells you what font size where

 

https://www.fda.gov/.../99151/download


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kingstudruler1

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Posted 26 January 2021 - 07:53 AM

omg - I still have nightmares of marketing personnel standing in my door way with label proofs. lol

I think you might be ok with the color.
(i) The nutrition information shall be set off in a box by use of hairlines and shall be all black or one color type, printed on a white or other neutral contrasting background whenever practical.

the slant is not ok - in my opinion. marketing people are also experts at parroting "this company does X"
id have to really scrutinize the label to tell if there are other issues. however, there is a rule for everything on the panel.

I also recommend purchasing the tool in the link below. it saved my sanity. marketing people are masters of altering the size / legal info so that they have room to tell the story about how the company is saving pandas in Nigeria.

https://acclabel.com...ducts/mesuracc/

if marketing wants to go off reservation, you should probably find a good label expert for review as the rules are vast and a little complicated.
im afraid to see the other panels. lol.

https://www.fda.gov/.../81606/download


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kingstudruler1

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Posted 26 January 2021 - 08:15 AM

I forgot to address the font issue.

Font for the entire label or the nutritional panel? you would be ok with different fonts elsewhere on the label but not within the nutritional
panel.


(ii) All information within the nutrition label shall utilize:
(A) Except as provided for in paragraph ©(2)(ii) of this section, a single easy-to-read type style,


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Kay-Pops

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Posted 27 January 2021 - 05:22 PM

I am currently looking at my 16 oz Redbull and there is a slight slant (no where near as drastic as your example), and the panel and font are blue on the silver background of the can. 

 

From what I remember, font type should be the same throughout the label. As far as black and white, if I remember correctly, it is just easy to read and 1 color. The panel requirements are laid out in CFR 101.9(d)(1). While it is confusing to understand at first glance in this instance its super important to understand so you can give appropriate feedback/push back to Marketing. 

 

When I was working with the marketing team on updating our panels, I tried to be very clear on the requirements set out in the CFR and had to push back a lot. In the end I shared the exact label specifications as written in the CFR so there was no confusion on my expectations and a reminder that I was not pushing back just to be difficult.

 

As some have already mentioned, it really helps to have an outside label expert to review the label, especially is Marketing is not relenting. Best of Luck!





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