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Labeling Requirements Suggested toppings

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Esoto728

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Posted 24 February 2023 - 10:39 AM

HI everyone,
 
Am looking for guidance on labeling of meat and poultry products, specifically frozen pizzas. Looked into the CFR codes etc but as we know sometimes there is a gray area or you end up with tunnel vision after reading so much. Customer is requesting on cheese pizza cartons print of "topping suggestions" no specific toppings are listed. We are kind of on the edge because our baking instructions are validated only for the build itself and not additional toppings. We would love to satisfy customer request but want to ensure we are able through CFR requirements and liability on our end. example is the following:

TOPPING SUGGESTIONS:

  • Prosciutto and finish with fresh basil
  • Shrimp, onion, peppers and finish with fresh arugula
  • Sausage, or bacon, olives, mushrooms, and green peppers
  • Thinly sliced potato and rosemary

Thoughts?

  
 
Thank you!


Edited by Esoto728, 24 February 2023 - 10:46 AM.


Evans X.

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Posted 24 February 2023 - 11:06 AM

Greetings Esoto,

 

This is more of a marketing issue with your customer. Many products have suggestions as to what they can be accompanied or supplemented with and if you go along with this you will have to be careful in declaring any possible health issues caused by these "suggestions", most notably allergens. You will have to put a disclaimer that some of the suggestions (if any of them is an allergen) may cause a reaction (like standard allergen labelling). Same would apply for health claims etc. Another disclaimer I would consider also would be the alteration of the baking conditions according to the toppings, although I guess most should be covered already (unless you suggest a stake on top!!!)

You don't have to provide extra details on the suggested ingredients of the toppings as they are to be added by the consumer if he chooses to.

However, my personal preference on these issues is that you can sign an agreement with your client that he will provide you with the labelling he wants and that he takes full responsibility in any event that may occur regarding this.

Of course you will have to have the agreement as well as the label template as evidence and I would also have a written statement of suggestions to the client by your company regarding what is legal to be written on a label, so you can cover yourselves legally.

 

In any way in your case making a suggestion statement on the label isn't really much of an issue, as long as you are careful with what I mentioned in the first paragraph.

 

Regards!


Edited by Evans X., 24 February 2023 - 11:08 AM.


Scampi

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Posted 24 February 2023 - 02:12 PM

A) the labelling needs to be accurate as does your nutritional fact table

 

B) you're required to declare allergens on the package

 

C) your labelling cannot be misleading

 

D)  adding meat and/or herb-veg WILL change your HACCP plan

 

E) you should validate your bake time again to ensure that what you've displayed is accurate


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Tony-C

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Posted 25 February 2023 - 05:01 AM

A) the labelling needs to be accurate as does your nutritional fact table

 

B) you're required to declare allergens on the package

 

C) your labelling cannot be misleading

 

D)  adding meat and/or herb-veg WILL change your HACCP plan

 

E) you should validate your bake time again to ensure that what you've displayed is accurate

 

Hi Scampi,

 

Are you sure this is true for a serving suggestion?

 

I would think that the best options for the pizza with"serving suggestions" on the packaging would be to have instructions for the customer to cook the pizza first as per the validated time/temperature then to add the serving suggestions and cook for a further x mins (just to heat up the ingredients).

 

Since they are only suggestions and you are not 100% sure what allergens are in the suggestions, why would you go there? For example, the meats the customer is putting on there may contain sulphites, would you want to be declaring sulphites as an allergen on the packaging if it was in the pizza? I don't think so.

 

Kind regards,

 

Tony





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