Form of ingredient to include on labels
Hi all!
We are a Canadian based company and are being audited to SQF level 2 standards.
I'm wondering for ingredient labelling, do I have to name the form that the ingredient is in? For example, can I just list "Thyme" or do I have to list "Dried thyme"? Another example we've run into, we use freeze-dried blueberries as an ingredient, should we be listing "Freeze-dried blueberries" or just "Blueberries" as an ingredient?
Thank you for the help,
-Kyra
I think it would be helpful to your company to make the distinction, yes. In your example, freeze-dried blueberries will have very different storage requirements than fresh blueberries. If an auditor were to review your records and see that you've had "blueberries" at room temp for 3 months they will likely ask some questions. You'd have to explain that they're actually freeze-dried.
Also, obviously, if you use both fresh blueberries -and- freeze-dried blueberries in your process you'll need to have a way of differentiating them. Separate material codes, certainly, but also simply naming them differently on the bag.
Thank you for the insight! I don't think I explained myself well, I'm only concerned about how it should be listed on the product label, in the list of ingredients, and what is required under CFIA labelling requirements. With that said, I agree with your point.
I think it would be helpful to your company to make the distinction, yes. In your example, freeze-dried blueberries will have very different storage requirements than fresh blueberries. If an auditor were to review your records and see that you've had "blueberries" at room temp for 3 months they will likely ask some questions. You'd have to explain that they're actually freeze-dried.
Also, obviously, if you use both fresh blueberries -and- freeze-dried blueberries in your process you'll need to have a way of differentiating them. Separate material codes, certainly, but also simply naming them differently on the bag.
Ah then unfortunately I am not familiar enough with CFIA labeling laws to know how it should be described on your finished product labels. I would expect you could simply list "Blueberry" or "Thyme", but I would wait for input from those more familiar with Canadian regs.
Annex VI of the EU labelling legislation states:
The name of the food shall include or be accompanied by particulars as to the physical condition of the food or the specific treatment which it has undergone (for example, powdered, refrozen, freeze-dried, quick-frozen, concentrated, smoked) in all cases where omission of such information could mislead the purchaser.
Source: https://eur-lex.euro...018:0063:en:PDF
I would therefore definitely specify freeze-dried for the blueberries, even if the CFIA doesn't require you to do so. It avoids accidentally misleading the consumer, it prevents awkward questions from auditors and confused consumers who want to know why blueberries can be stored for months without molding and it significantly eases export should that ever happen. For thyme I don't feel mentioning the ingredient's state is necessary as it wouldn't be misleading. In fact, I haven't specified it on any products I've written the ingredient list for in several years except where the product was something like 100% powdered thyme instead of 100% non-powdered thyme.
Remember that the labelling rules are there to provide clarity to the consumer and prevent misleading them and work on that basis.