4 replies to this topic

[LGreen]

I have been researching on the FDA labeling sites for the proper usage of film during a reformulation process change.  I'm new to this topic, but want to make sure we follow the correct guidelines and legal requirements of prior film to new film during a reformulation recipe change.  Are we allowed to use up the old film with the new formulation and if so - is there a "grace period" while we are waiting for the new film with the updated nutritional label?  The FDA Labeling Guidelines is very intensive to read and fully understand and we need to make sure to do this correctly. 

 

Any help and guidance would be appreciated before we move forward with any changes. 

Thanks

[kingstudruler1]

i dont know of any grace period.  The label needs to accurately reflect the product.  

[G M]

Can't speak specifically for FDA, but there are limited allowances for this in USDA products.  The nature of the change may play a significant role in what is allowed, where deletions are less of a risk than additions.

[kfromNE]

You need a hard cut off date. No grace period. Use the old formulation process until new labels come in. Then switch over. 

USDA does allow for variances of labels but with permission from the USDA. Usually on a temporary basis. 

 

You could ask the FDA. However - it takes a while to hear back from them. 

[chrkut]

If the film is what has the Nutritional Facts panel on it, and the reformulation change is enough to change the NF panel or ingredients list, you cannot begin using the new formula until the new film is in.