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Ingredient Claims in Food Labeling: Legal Guidelines

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SLopez

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Posted 05 September 2024 - 12:25 AM

I was reading about ingredient lists today and saw that you could put "organic" before an ingredient. For example, the ingredient list went: Water, Organic Sugar, Organic Tomato... I was wondering if something like this would be possible for other types of claims, like could I put "Gluten Free Soy Sauce, Water, Sugar..." in an ingredient statement? Or in something like a frozen quiche, could an ingredient statement say "Cage Free Eggs, Milk, Cheddar Cheese..." Or even something like "Flour, Vegan Butter (Oil Blend, Emulsifier, etc.), Salt..." and would it be legal (in the eyes of the FDA)? Is there a list of claims, besides organic, that you could include in an ingredients list?


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Setanta

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Posted 05 September 2024 - 11:52 AM

That's a good question! I wish I had an answer for you, but if someone doesn't know here, best check with the FDA or the USDA. Do you approve all of your own labels, or do you have a company you work with? They should know.


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kconf

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Posted 05 September 2024 - 11:59 AM

You can make such claims as long as the entire product holds its meaning. In some cases you may not even need such claims if you are already marketing it that way. 

 

For example, if your product is marketed "organic" then you don't need to list all your ingredients organic this, organic this, organic that. If you are already using everything organic then just call it an organic product. 

 

Hope this helps. Good luck!


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MDaleDDF

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Posted 05 September 2024 - 01:07 PM

I agree with Kconf, and if it were me and it was already labeled that way on the packaging, I wouldn't personally put it in the ingredient statement as well in the name of simplicity.


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Scampi

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Posted 05 September 2024 - 02:15 PM

Among the claims that can be used on food and dietary supplement labels are three categories of claims that are defined by statute and/or FDA regulations: health claims, nutrient content claims, and structure/function claims. Learn more about these categories from Label Claims for Conventional Foods and Dietary Supplements.

 

 

Organic is a regulated statement that has it's own rules regarding the ingredient label and how it appears

The USDA requirements for products that are labeled with the term "organic" are separate from the laws that the FDA enforces. Food products that are ordinarily under the FDA's jurisdiction and labeled with organic claims must comply with both USDA NOP regulations for the organic claim and FDA regulations for food labeling and safety.      https://www.ams.usda...lations/organic

 

As for your other questions, items like MILK and BUTTER  and EGGS have a standard of identify legally speaking and i'm not convinced you could add anything to it


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SLopez

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Posted 05 September 2024 - 04:42 PM

That's a good question! I wish I had an answer for you, but if someone doesn't know here, best check with the FDA or the USDA. Do you approve all of your own labels, or do you have a company you work with? They should know.

This is more of a hypothetical question, though it would be nice to know in case it ever comes up with us. We typically keep the claims elsewhere on the label instead of in the ingredients list. 


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SLopez

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Posted 05 September 2024 - 04:55 PM

You can make such claims as long as the entire product holds its meaning. In some cases you may not even need such claims if you are already marketing it that way. 

 

For example, if your product is marketed "organic" then you don't need to list all your ingredients organic this, organic this, organic that. If you are already using everything organic then just call it an organic product. 

 

Hope this helps. Good luck!

I see what you mean. In a similar vein, I see that it wouldn't make sense to have a statement say "Organic Sugar, Gluten Free Soy Sauce (Water, Soybeans, Salt), Wheat..." when there's no claims elsewhere on the item's label. 

 

How about in the case of an item labeled as "Gluten Free Teriyaki Sauce" having "Gluten Free Soy Sauce" in the ingredients statement since soy sauce is typically a suspect for gluten content? Or in a "Non GMO Soup" item having "Vegetable Stock, Non GMO Cornstarch..." in its ingredients list since cornstarch is typically suspect for GMO sources? May be a bit nitpicky, though its all from curiosity. 


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SLopez

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Posted 05 September 2024 - 04:59 PM

You can make such claims as long as the entire product holds its meaning. In some cases you may not even need such claims if you are already marketing it that way. 

 

For example, if your product is marketed "organic" then you don't need to list all your ingredients organic this, organic this, organic that. If you are already using everything organic then just call it an organic product. 

 

Hope this helps. Good luck!

I see what you mean. In a similar vein, I see that it wouldn't make sense to have a statement say "Organic Sugar, Gluten Free Soy Sauce (Water, Soybeans, Salt), Wheat..." when there's no claims elsewhere on the item's label. 

 

How about in the case of an item labeled as "Gluten Free Teriyaki Sauce" having "Gluten Free Soy Sauce" in the ingredients statement since soy sauce is typically a suspect for gluten content? Or in a "Non GMO Soup" item having "Vegetable Stock, Non GMO Cornstarch..." in its ingredients list since cornstarch is typically suspect for GMO sources? May be a bit nitpicky, though its all from curiosity. 


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kconf

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Posted 05 September 2024 - 06:26 PM

when a product says "non GMO", it is made with non GMO ingredients. 

 

If soy sauce contains gluten, it says on the label. If sauce contains no gluten (in any of the ingredients) then it can be labeled as gluten free

 

Adding such things to ingredients list does not add much value. Consumers care about the overall product first, then they will look at the ingredients list. 


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