6 replies to this topic

[TAW]

In the process of doing some label reviews and getting updated specification sheets from our suppliers; we noticed that one of our suppliers changed the Nutritional Facts on their spec sheet.  The previous specification sheet's nutritional ingredients was based on old data that the manufacturer had.  The main issue is that the new Nutritional Facts are actually half as much as the previous one.  For example: the serving size is 10 grams now but the previous one was 20g.  So our custom labels still have the 20g serving size (we are in the process of updating them now); and we do not have any of this product in stock right now to be able to even use the old labels even if we wanted to so we will have new labels on our end before we get new stock.

 

This is a gap in my knowledge that I just want to fill in.  What is the guidance on having labels that are actually double the amounts of what is in the package?

[Brothbro]

For clarity, was the formula of the product changed in any way, or simply the serving size? 

 

Either way, the nutrition facts labels on your product do need to be accurate. For this scenario, I mean that they need to list a serving size followed by a number of servings per container based on the net weight. If your net weight is 20g, and the serving size is 10g, your nutrition facts label can list nutrients in amounts that are in a 10g serving but the table also needs to list that there are 2 servings per container.

 

The reverse of this scenario, to my knowledge, is not acceptable. If your net weight is 10g, you should not list your serving size as 20g followed by nutritional information for a 20g serving.

 

The FDA's food labeling guide can be downloaded from this link, it's a decent sized read but has answers to questions that many people have:

https://www.fda.gov/...-labeling-guide

Edited by Brothbro, 29 November 2023 - 04:59 PM.

[TAW]

Just the serving size.  No formula change.  The only difference is that the manufacturer label says 1 serving size is 10g and ours says 1 serving is 20g and the nutritionals are scaled correctly.

[jfrey123]

If the ratios are unchanged, I don't necessarily see a reason for you to amend your labels.  If you're still using the same amount of their product for your inputs, nothing should technically change on your end.

 

I know a lot of manufacturers needed to change their labels based on the FDA's guidelines for RACC's (reference amounts customarily consumed), which is why candy bars now have those dual labels showing information for one serving of the bar vs the whole package.  Could be your supplier switched to align with that RACC portion, and might be worth checking that your product is showing the recommended serving size as well:

 

eCFR :: 21 CFR 101.12 -- Reference amounts customarily consumed per eating occasion.

 

Guidance for Industry: Food Labeling: Serving Sizes of Foods That Can Reasonably Be Consumed At One Eating Occasion (fda.gov)

[Brothbro]

Just the serving size.  No formula change.  The only difference is that the manufacturer label says 1 serving size is 10g and ours says 1 serving is 20g and the nutritionals are scaled correctly.

 

Do you have any response from the manufacturer on why the serving size was changed? According to regs, manufacturers must use the information provided in the FDA's "Reference Amount Customarily Consumed (RACC)" as a starting point to determining the serving size in their product. It could be that the manufacturer has revised their serving size based on this information, which in turn may prompt you to make similar changes if you're simply repacking their product.

[TAW]

Yes, basically they said that when they bought the recipe for the item from another manufacturer, that manufacturer mistakenly gave them the nutritional facts for a larger size and not the size they planned on producing them at.

[Brothbro]

You do have options if your product is sold as a "single serving package". It could be that you would not need to change your labels at all if you are within a certain amount of the RACC and a small enough package size (less than 200% of the RACC). There are situations where you can determine your serving size based on the fact that it is reasonable to consume the entire package contents in a single sitting. I would recommend reading the serving size sections in the document I referenced in post #2, this spells out some the rules in setting your serving sizes.