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Do all ingredients need to be declared in the ingredient statement (non allergen)?


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#1 joannaflesche

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Posted 18 May 2021 - 02:12 AM

Hello all, I am new to all of this. Do all ingredients need to be declared in the ingredient statement (non allergen)? We are performing a formula change to include some IQF peas and I am looking for documentation to support not having to edit the ingredient statement immediately (we have a lot of labels on hand with our old formulation and will not reprint for another month or so). Any help is appreciated! Thanks, Joanna

 



#2 Scampi

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Posted 18 May 2021 - 12:04 PM

?????? Ah yep

 

Just because an item isn't on the list of allergens that must be declared does NOT mean you can choose to omit an ingredient!

 

You MUST declare all ingredients, so you have 2 choices-delay reformulation until you've used your label inventory up or eat the label cost to dispose of them

 

These are LEGAL requirements, your end consumer could be allergic to peas and you'd be liable

 

I have to say, I'm shocked by the questions posted on here lately 

 

§ 101.4Food; designation of ingredients.(a)(1) Ingredients required to be declared on the label or labeling of a food, including foods that comply with standards of identity, except those ingredients exempted by § 101.100, shall be listed by common or usual name in descending order of predominance by weight on either the principal display panel or the information panel in accordance with the provisions of § 101.2, except that ingredients in dietary supplements that are listed in the nutrition label in accordance with § 101.36 need not be repeated in the ingredient list. Paragraph (g) of this section describes the ingredient list on dietary supplement products

 

You NEED to get comfortable reading and understanding regulations


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#3 kfromNE

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Posted 18 May 2021 - 12:27 PM

You need to declare the peas. You can't use the old labels. One exception to labeling items are spices. You can say spices on a label without saying what they are. Unless it is an allergen.



#4 TimG

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Posted 18 May 2021 - 01:38 PM

Good morning Joanna! Regulatory questions like this are pretty impactful to your company, both in repercussions if you fail to meet the law as well as possible costs involved in meeting the law.

If your company has made you responsible for maintaining your labels I STRONGLY suggest you get some training on what's required as well as reach out to a regulatory law group and open a dialogue. I have a corporate global regulatory director whom I can go to and he is extremely knowledgeable. We still need to reach out to our regulatory law advisors on occasion.



#5 dgt39

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Posted 19 May 2021 - 07:43 AM

Bit of a strong response from Scampi. As Joanna says she is new to this. She will probably think twice before asking for help again on this forum.



#6 Charles.C

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Posted 19 May 2021 - 11:14 AM


Attached File  pea allergy.png   296.05KB   0 downloads

 

(UK, 16/3/2020)

 

Attached File  FDA Food-Labeling-Guide-(PDF).pdf   8.49MB   3 downloads


Kind Regards,

 

Charles.C


#7 Scampi

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Posted 19 May 2021 - 12:58 PM

dgt39   I hope Joanna does ask for help again on this forum, but I also hope she learns to understand the gravity of what we do and the harms that come from our jobs being sloughed off as unimportant

 

I want her to learn, and grow and make good decisions based on facts, and the fact is we all need to be able to understand regulatory requirements, where to find them and how to read them


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#8 Setanta

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Posted 19 May 2021 - 01:07 PM

Bit of a strong response from Scampi. As Joanna says she is new to this. She will probably think twice before asking for help again on this forum.

 

 

It is a strong response, but it is a HUGE legal thing the OP is proposing. It isn't just about unhappy customers, but an actual recall, should this get out into the market.  That alone could sink a company,   Companies and people need to realize this isn't a game.  


-Setanta         

 

 

 


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#9 dgt39

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Posted 19 May 2021 - 02:59 PM

'Companies and people need to realize this isn't a game.'  

 

Who said anything about it being  ' a game'.

Everyone  using IFSQN understands how 'HUGE' this is.

Person asking for help got abrupt responses.

Could have been a little more empathy?

Having said that I did find your responses instructive and learnt something myself :)



#10 Setanta

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Posted 19 May 2021 - 03:15 PM

My heart is with people that companies try to bluff into thinking something is 'No Big Deal'

 

I won't speak for Scampi, but I am coming from a "Scared Straight" perspective of making folks aware that this can have serious repercussions.

 

If you don't know that adding a non-allergen ingredient without changing the labels in the US is a big deal, you may not know that recalls can end up closing companies and laying off workers permanently.

 

(I suppose I should NOT add that QA Managers have served jail time for letting things go that the Big Boss said to 'let go'...)


-Setanta         

 

 

 


#11 Scampi

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Posted 19 May 2021 - 06:03 PM

I little window into me-----I worked for a company that was responsible for deaths resulting in a massive recall (largest in Canadian history--read the whitepapers written about it). I still think about the lives lost---and that company was following BEST PRACTICES for the time/product. I know how it feels, and I don't want anyone to have to go through that again, feeling like you've contributed to someone's death.......so yeah, I take my job very seriously, as I hope everyone else does as well

 

Joanna-- our intention here is to help and assist whenever we can.  It's also to support one another so we can rest easy at the end of each working day knowing we've done all we possibly can

 

Lots of folks new to this industry are hired because they are easily pushed around--hence my comments about making sure you've educated yourself, so that you can support your arguments back

 

I've been at this a long time, and I've left employers due to these tactics. Never sacrifice your personnel integrity for a job

 

We can't always prevent bad actors from producing and selling potentially harmful food, but we don't have to help them


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#12 TimG

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Posted 19 May 2021 - 06:55 PM

Scampi in here keeping it real, and speaking to my soul...



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