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Use of QR Codes for Nutritional Labeling


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nicfarmer12

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Posted 01 December 2021 - 04:01 PM

Hi everyone!

 

I am looking for some guidance on nutritional labeling and using QR codes. We are fixing to put in an order for boxes and we want to get this right so that we do not end up with thousands of boxes we can no longer use. 

 

We produce a nicotine and tobacco free moist snuff alternative. Our product is made with tea leaves, mint leaves, and coffee. We are considered food since the product is put in the mouth BUT it is not ingested, just the juice is (sounds very strange). 

 

So, what I am struggling with is nutritional labeling and panel. Can we use a QR code in place of the nutritional panel? I am reading through the FDA Labeling Guide but I am not finding my answer! 

 

Anyone have any guidance here? 

 

Many Thanks,

 

Nicole 


Nicole Farmer

 


kfromNE

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Posted 01 December 2021 - 04:07 PM

Not sure the exact answer. However the size of your company (in dollars) and the size of your package will be part of the determining factor.



nicfarmer12

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Posted 01 December 2021 - 04:12 PM

Not sure the exact answer. However the size of your company (in dollars) and the size of your package will be part of the determining factor.

 

Do you know where I would find that information at about the size of the package being part of the determining factor?


Nicole Farmer

 


Scampi

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Posted 01 December 2021 - 05:57 PM


Please stop referring to me as Sir/sirs


kingstudruler1

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Posted 02 December 2021 - 01:01 AM

without an exemption of some kind the answer is that it would not be allowed.  

 

BTW what the heck is the reference amount customarily consumed?

 

another possible exemption is:  (please don't use this with our consulting with a regulator or legal expert)

(4) Except as provided in § 101.11, foods that contain insignificant amounts of all of the nutrients and food components required to be included in the declaration of nutrition information under paragraph © of this section, Provided, That the food bears no nutrition claims or other nutrition information in any context on the label or in labeling or advertising. Claims or other nutrition information, except as provided in § 101.8©, subject the food to the provisions of this section. An insignificant amount of a nutrient or food component shall be that amount that allows a declaration of zero in nutrition labeling, except that for total carbohydrate, dietary fiber, and protein, it shall be an amount that allows a declaration of "less than 1 gram." Examples of foods that are exempt under this paragraph include coffee beans (whole or ground), tea leaves, plain unsweetened instant coffee and tea, condiment-type dehydrated vegetables, flavor extracts, and food colors.


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