Additional Net Contents Declarations?
Hi all. I made the switch from pickles to gift boxes and gift sets. What we make here involves taking pre-packaged ambient, shelf-stable foods--mostly RTE items, but some sets may include pancake mix, for example--and putting them together into gift baskets, boxes, etc.
One of our packaging designers asked me something that has me stumped. For Net Weight declarations on these types of assorted food items (gift baskets, box sets), is there a standard on where Net Weight should be displayed or disclosed on the gift tag?
We have a couple of items where the Total Net Wt. is declared on both sides of the tag. On others, the Total Net Wt. is declared on the front OR on the back. I don't think it matters too much as long as it's declared appropriately and the total contents (including mugs, cups, whatever non-edible thing) are disclosed. But I am new to the land of "multiple foods packaged together," so I wanted to see if I was missing anything. I couldn't find anything on FDA or FCC or NIST that gave a clear enough answer for this very niche area.
Generally, 21 CFR 101.7 states that net weight must be declared on the "principle display panel". What do you consider your principle display panel on your gift baskets? I can see how this can get complicated, especially since most gift baskets are simply a basket filled with goods and covered in clear plastic. The FDA considers the principle display panel to be the part of a food label that is most likely to be seen by a customer when the product is for sale (the front of the product). If your tag is clearly visible from the front of the gift basket, this may constitute a principle display panel, and would be where your net weight declaration should go. If not, you may need some kind of insert to the front of the basket that indicates the net weight of the product (or re-position the tag).
I do agree though that it's a complicated issue, let's see if anyone else has experience in this area.
Generally, 21 CFR 101.7 states that net weight must be declared on the "principle display panel". What do you consider your principle display panel on your gift baskets? I can see how this can get complicated, especially since most gift baskets are simply a basket filled with goods and covered in clear plastic. The FDA considers the principle display panel to be the part of a food label that is most likely to be seen by a customer when the product is for sale (the front of the product). If your tag is clearly visible from the front of the gift basket, this may constitute a principle display panel, and would be where your net weight declaration should go. If not, you may need some kind of insert to the front of the basket that indicates the net weight of the product (or re-position the tag).
I do agree though that it's a complicated issue, let's see if anyone else has experience in this area.
Yeah, we even had our PD team go out and check how our competitor's label their gift baskets to see if we were too "overkill," but results were mixed. Some had the info on the gift/price tag AND on a paperboard insert in the back; some had it on both sides of the gift/price tag...my thoughts are that because the standard is a little vague, everyone is just trying to cover all possible bases.