Hello,
I need some guidance from you all regarding ingredient statement.
I looked at FDA regulations 21 CFR 101.4 Food; Designation of Ingredients but I need some clarification.
So, we add ingredients and sub ingredients to our statements but we do not add the sub ingredients in parentheses. Per the regulations there are two options:
(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.
As I understand the first option is to put sub ingredients in paranthesis. I do not completely understand the second option but I do believe that is the way we are doing it.
Example Ingredient Statement we do: Wheat Flour, Malted Barley Flour, Niacin, Iron, Thiamin Mononitrate, Riboflavin, Folic Acid, Butter, Natural Flavor, Sugar, Egg, Water, Glycerin, Ethyl Alcohol, Acacia Gum, Xanthan Gum, Salt. Contains Wheat, Eggs and Milk.
The wheat flour is the ingredient and Malted Barley Flour, Niacin, Iron, Thiamin Mononitrate, Riboflavin, Folic Acid are the sub ingredients. Can we list them like I wrote it above or do we need the parentheses?
We also use Nat. Vanilla Flavor and on the spec sheet only the sub ingredients are listed (highlighted in blue) not sure if we need to include it as Natural Vanilla Flavor (sub ingredients).
Please help!
Thank you all in advance!