How to Label Aromatics Removed From Flavored Oil Before Bottling
Hello,
I developed a chili oil that is cooked with dried aromatics/chilies that are then strained out prior to bottling. Only the flavored oil (with no particulates) is bottled as a finished product. Do I need to list the aromatics that are removed? I'm thinking some of them fall under "Natural Flavor" but when it comes to garlic, onion, etc. I'm not sure that would fall under natural flavor. I know some people can have sensitivities to alliums and I don't want to hide anything, I just want the label to be correct and safe.
Maybe my search terms are wrong but I can't seem to find any FDA guidance on this one. Any help would be appreciated.
This is an interesting topic and I am excited to see what others think.
Do you have any objection to labeling all of the ingredients you used to make the oil?
I think that would be the simplest solution. Here is an example of a strained chili oil that lists the chilis and paprika in the ingredients.
https://www.bokksuma...ign=sag_organic
Here is the FDA list of spices that can be labeled as "spices" on the ingredient list:
https://www.ecfr.gov.../section-182.10
21CFR101.22(a)(1) is where I found this.
FDA's "Hazard Analysis and Risk-Based Controls for Human Food" also has some interesting points.
For infused oils, chili pepper oil specifically, undeclared allergens are not an identified risk. This will change, of course, if you're infusing with something allergenic or export to a country where it is allergenic.
Page 191 > https://www.fda.gov/.../99581/download
I would list all the ingredients unless you can prove that is on the gras list. You can petition the FDA but is lengthy process and usually requires data to validate.
This is an interesting topic and I am excited to see what others think.
Do you have any objection to labeling all of the ingredients you used to make the oil?
I think that would be the simplest solution. Here is an example of a strained chili oil that lists the chilis and paprika in the ingredients.
https://www.bokksuma...ign=sag_organic
Here is the FDA list of spices that can be labeled as "spices" on the ingredient list:
https://www.ecfr.gov.../section-182.10
21CFR101.22(a)(1) is where I found this.
FDA's "Hazard Analysis and Risk-Based Controls for Human Food" also has some interesting points.
For infused oils, chili pepper oil specifically, undeclared allergens are not an identified risk. This will change, of course, if you're infusing with something allergenic or export to a country where it is allergenic.
Page 191 > https://www.fda.gov/.../99581/download
Thank you for the info and the links you've provided. Taking a look through everything now. I agree that the simple solution is listing each ingredient in typical descending order, I just didn't know if it would be a no-no to label it as having all of these spices in it when what the end consumer will be using is just oil. Is it a misrepresentation if the ing. statement has a long list of ingredients like spices, dried mushrooms, garlic, onion, etc. but the ingredients aren't actually present in the sauce?
Can we put "extract" at the end of each ingredient? Thinking "CHILI EXTRACT, SPICE EXTRACT, DRIED SHIITAKE MUSHROOM EXTRACT (etc.)" like the first label you linked to.
An idea that many small companies do. Look at similar products made by major brands and see how they do it.
As to sensitivities to alliums - you don't have to do anything label wise from a regulatory stand point. People are allergic to all kinds of foods.
From my experience, people will contact a company if they are allergic to foods not required to be labeled by law and they are unsure.