Product White Labelling-Product Relabel Only

Good Morning Fellow Food Safety Warriors,

I have a question I have been getting some conflicting information on so I thought I would put the question to IFSQN...

I work at a FDA/USDA food manufacturing facility in the US. Our ops manager told me today that he has an opportunity for a new product. The new product process is as follows:

1. Receive shelf-stable master cases of pasta

2. Remove original manufacturer's label

3. "White Label"/Put our own label on the master cases (I'm not sure of the intent to relabel the individual units within the master case).

4. Ship to a customer for further distribution/their own internal processes

My questions are:

1. Is this legal in the US if the original manufacturer of the pasta has not been notified of the change?

2. Are there any additional white labeling regulations/laws that we need to be aware of in order to relabel this product?

3. "Insert other questions here that I have not thought to think of yet". :)

Thanks in advance everyone!!!

Update: 

So I just confirmed that there are no individual units inside the master case. This is a bag-in-a-box item with the master case label being the only product label. This is also a food service item and is NOT being shipped out for retail.

its hokey, but legal.  

1. no you don't need to legally notify the original MFG.   It's your product.   from a business standpoint you could piss your supplier.   

2. no, just regular labeling laws.  

3.   i have worked at place where part of the business was just repacking product.  From time to time, they would attempt to do what you are looking at doing.  It usually looks like crap.