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Do we need to list the individual ingredients for the sauce on the label?


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Miss Frankie

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Posted 12 April 2022 - 06:18 PM

We still produce imitation crab made from surimi.  

On our label, if we add a sauce for flavor while making the product, do we need to list the individual ingredients for the sauce?

We add Mirin, which is a rice wine. It is on the the ingredients listed as less than 2%. 

 

I went thru the whole FDA labeling guide and didn't find anything on it.... but I may have gone cross-eyed part way thru and missed it.

 

Thanks!



kingstudruler1

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Posted 12 April 2022 - 07:36 PM

Yes.  you would have to include all of the ingredients in the sauce.   Ex "x" sauce (water, Milk, spices, etc)

 

I'm not sure what your question is for mirin.  I would expect it to be listed as: Mirin (water, rice, Koji (aspergillus oryzae), salt. (Or whatever yours is made of).  even if only 2% or less


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Miss Frankie

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Posted 12 April 2022 - 08:15 PM

Yes.  you would have to include all of the ingredients in the sauce.   Ex "x" sauce (water, Milk, spices, etc)

 

I'm not sure what your question is for mirin.  I would expect it to be listed as: Mirin (water, rice, Koji (aspergillus oryzae), salt. (Or whatever yours is made of).  even if only 2% or less

Thank you.

 

I've only been here since December, so I'm still learning all the intricate labeling things.
Some labels they have Mirin (rice wine), others have Mirin (water, rice wine, sugar and lactic acid).

 

Do you have a link to a regulation I can show them?  They like real proof of things like this.   There is a bit of a language barrier between upper management and the rest of the staff, it can make things difficult at times.



kfromNE

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Posted 13 April 2022 - 12:01 PM



kingstudruler1

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Posted 13 April 2022 - 05:10 PM

Thank you.

 

I've only been here since December, so I'm still learning all the intricate labeling things.
Some labels they have Mirin (rice wine), others have Mirin (water, rice wine, sugar and lactic acid).

 

Do you have a link to a regulation I can show them?  They like real proof of things like this.   There is a bit of a language barrier between upper management and the rest of the staff, it can make things difficult at times.I

 

I understand.  These laws are not easy to learn and in some cases easy to find.   I took me a long time in the fire (where you are) to figure it out without much help. there was nothing more frightening to me then the sales and marketing people showing up in my office with a stack of labels for approval.    i dont know how many times I said or wrote 1/16th measure by the lower case "o".  

 

I HIGHLY recommend the following for font sizes.    its a life changer.  https://acclabel.com...ducts/mesuracc/

 

I have also posted a link to the labeling guidance.    in case you dont have it.  its a good place to start.   

 

Food Labeling Guide (fda.gov)

 

If you want to send me all of the info, can probably review the labels for you.   im sure others would be glad to do this as well.  

 

 

any way 

 

21 CFR 101.4(b)(2)

An ingredient which itself contains two or more ingredients and which has an established common or usual name, conforms to a standard established pursuant to the Meat Inspection or Poultry Products Inspection Acts by the U.S. Department of Agriculture, or conforms to a definition and standard of identity established pursuant to section 401 of the Federal Food, Drug, and Cosmetic Act, shall be designated in the statement of ingredients on the label of such food by either of the following alternatives:

(i) By declaring the established common or usual name of the ingredient followed by a parenthetical listing of all ingredients contained therein in descending order of predominance except that, if the ingredient is a food subject to a definition and standard of identity established in subchapter B of this chapter that has specific labeling provisions for optional ingredients, optional ingredients may be declared within the parenthetical listing in accordance with those provisions.

(ii) By incorporating into the statement of ingredients in descending order of predominance in the finished food, the common or usual name of every component of the ingredient without listing the ingredient itself. 


Edited by kingstudruler1, 13 April 2022 - 05:13 PM.

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