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Nutrition Label on box versus label on website only


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ESuttmiller

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Posted 16 April 2021 - 09:35 PM

Hello,

 

We are a wholesale raw nut supplier and recently we have started to look into selling boxes (30#) to consumers directly via e-commerce. My question is if it is ok to simply have the nutrition label on our website or is it required to also be affixed to our box.  I would love references to back up your answers as the higher ups are asking for it. 

 

My gut says to have it in both locations, but I want to make sure before I tell them one way or the other and also to have documentation to back my answer up. 

 

 

Please help. 



drk0904

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Posted 17 April 2021 - 03:48 AM

Hi @ESuttmiller,

 

 

It will depend on your country of operation/sale and whether they have any regulation related to E commerce sale.

 

 

 



adnuf

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Posted 18 April 2021 - 03:49 PM

Hi @ESuttmiller,

 

 

At a commerce sale  it is ofcourse depends  on your country regulations . But I think we also think like consumer , we are also consumer . So it is better both written  on the  box and   in the web site not just only for the regulations . if you have a problem about box size . Than you don't have a chance  to write on box may be . in this case you can gives this information with delivery paper also . 



adnuf

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Posted 18 April 2021 - 04:05 PM

@ESuttmiller,

 

You can also  search  "distance selling"  in  nutritional labelling.  

 

You may find that kind of guides ;

 

 

https://assets.publi...al_Guidance.pdf

 

https://www.fooddrin...uidance_WEB.pdf

 

 

Regards

 

https://www.fda.gov/...-labeling-guide



ESuttmiller

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Posted 19 April 2021 - 02:00 PM

We are based in the US. We sell primarily to US companies, We have sold to Mexico and Canada in the past. This is our first foray into direct to consumer and not straight to companies that do other things with our raw agricultural commodity (Pecans).



Scampi

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Posted 19 April 2021 - 02:11 PM

In Canada, ALL food for purchase (regardless of the platform) must meet our regulatory requirements---so each unit is legally required to have a NFT on it


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olenazh

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Posted 19 April 2021 - 02:18 PM

As per Canadian regulation (B.01.001, B.01.401(1), FDR), NFT shall be indicated on a product label if it's not an exception which your product doesn't seem to be.



ESuttmiller

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Posted 19 April 2021 - 02:21 PM

Got clarification from the higher ups. It will not be shipped to Canada at this time. Looks like its domestic (US only) right now. The question is not whether or not to have one, its where it needs to be located. :  



Scampi

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Posted 19 April 2021 - 02:26 PM

https://www.govinfo....ol2-part101.xml

 

All the info you need is here (unless your product is USDA and not FDA)

 

ii) The information required by paragraph (b) of this section appears on the label in accordance with the provisions of this paragraph, except that the type size is not less than 1/32 inch in height.(d)(1) Except as provided by §§ 101.9(j)(13) and (j)(17) and 101.36(i)(2) and (i)(5), all information required to appear on the principal display panel or on the information panel under this section shall appear on the same panel unless there is insufficient space. In determining the sufficiency of the available space, except as provided by §§ 101.9(j)(17) and 101.36(i)(5), any vignettes, designs, and other nonmandatory label information shall not be considered. If there is insufficient space for all of this information to appear on a single panel, it may be divided between these two panels, except that the information required under any given section or part shall all appear on the same panel. A food whose label is required to bear the ingredient statement on the principal display panel may bear all other information specified in paragraph (b) of this section on the information panel.


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johnmcip

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Posted 19 April 2021 - 08:43 PM

If you are in the united states you may not be required to include nutrition facts on the boxes. See here

Are nuts considered "raw fruits, vegetables, and fish"?

Now I don't know if this matters, but very very few consumers are buying 30lb cases of raw nuts, I would wager a bet that the most likely buyers would be small restaurants and hobby bakers. Whether that matters I'm not sure.



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ESuttmiller

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Posted 19 April 2021 - 08:58 PM

John, I don't think we fall under the exemption at least when we are selling direct to consumer. I agree. I think its not going to have a big impact. But, it's what the higher ups thought was a good idea. I've gotten some clarification from some other sources and it looks like I'm correct in my thinking. 



QA & R Miller

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Posted 19 April 2021 - 11:13 PM

John, I don't think we fall under the exemption at least when we are selling direct to consumer. I agree. I think its not going to have a big impact. But, it's what the higher ups thought was a good idea. I've gotten some clarification from some other sources and it looks like I'm correct in my thinking. 

 

I agree that if you are shipping the 30# box directly to the consumer, you should include ingredient statement and nutrition facts printed on a sticker affixed to the case. If you are putting that case into another shipping box, you could affix an insert with the information (tape it?) or if it is the only case in the shipping box the insert could be loose. 



johnmcip

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Posted 20 April 2021 - 09:23 PM

I agree that if you are shipping the 30# box directly to the consumer, you should include ingredient statement and nutrition facts printed on a sticker affixed to the case. If you are putting that case into another shipping box, you could affix an insert with the information (tape it?) or if it is the only case in the shipping box the insert could be loose. 

 

 

"Should" or "must" are different.

If adding leaflets to each box manually becomes too burdensome, or even more important, you aren't confident that you'll get the right one in 100% of the time, its good to know if its even required in the first place. I don't know where nuts stand in relation to the FDA/USDA and their regulations, but if they are indeed "raw fruits and vegetables", I would maintain that an online copy is enough.

You could however add a QR code to the case as a direct link to the nutrition facts. If you don't want to be stuck with nonconforming inventory if something changes, or stocking preprinted cartons for each SKU, another option would be for the CQ code to link to a page that allows them to search your products.



Fishlady

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Posted 23 April 2021 - 10:12 PM

I had a similar dilemma with a company I previously worked for, where they decided to sell frozen seafood (fillets and portions) directly to consumers.  I advocated that we needed to put nutrition labels on the box, but the company overruled me and decided it was sufficient to have the information only on the website.  To my knowledge they have not yet gotten into trouble with FDA, but I wonder if that is simply because FDA has not looked at them yet...






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