Private Label Product Shipping Without Full PDP – FDA Compliance?

Hello, 

Would be fine as a manufacturer for private label to dispatch product with only a label that contains the nutritional information, ingredients statement, allergen, manufacturer, weight and upc on the bottom of the container? This is for a ready to eat salad. 

The customer would like to place the label with their logo once they put the product on their shelf. Basically, when leaving the manufacturing facility; it wont have a PD panel but will have information panel.

Do you think that would be acceptable based on FDA requirements? 

Thank you. 

Ana 

If this is manufactured for your private label customer and they technically own it, the responsibility and onus is on them to place the PD label on.  You are preparing a package that needs further labeling downstream which is compliant, you have all the regulatory information on the back panel.  This seems to be more a marketing/branding concern.  Do you state on the rear panel who manufactured the product or that product was manufactured for XXX brand?  If so you should be all set and would look to see that this was in an agreement/contract somewhere as far as who takes ownership just to CYA.  

Yes that would be fine.

One thing however since they are finishing with their label - is your company shown as the "manufacturer" straight or are you noting their info and noting that the product was made for XYZ, etc.?

Thank you both for answering my question. 

The manufacturing information states: Manufactured for " XYZ" and the customer corporate address. 

It meets all regulatory requirements you should be all set. 

All the best!