Date Coding Inner Pouches vs. Retail Boxes: Compliance with Labeling Laws
Is it okay putting the manufacturing Julian date on the inner pouches and then the expiration date on the retail boxes (as we have), or are we are required to have them match?
Based on what you've said here, it is your decision to make how to format your date codes. If you are making your own product, and do not have to adhere to standards for anyone else, like Costco Sam's Club or Walmart.
If the pouches can't be divided up and sold individually, you should be OK. Of course, there are regulatory issues to consider. Is it meat or seafood or dairy or fruit?
Is it okay putting the manufacturing Julian date on the inner pouches and then the expiration date on the retail boxes (as we have), or are we are required to have them match?
I would think legally you would need the expiration date on any packaging which could be sold to a consumer and it would be advisable even if only sold as a box from business to business.
If you're asking if the Julian code as an additional code can be missed off the box, yes, I would think so as long as the date code can be used to trace if needed.
Is the box or the pouch the consumer unit?
For some of our non-fresh items (crackers, pretzels, etc), the clear inner pouches are only labeled with the product name and a lot code, while the outside case is where all of the b2b information was labeled on the box. Helps ensure traceability if we remove the pouches to stage on our production lines to fill fruit and veg trays.
Back when I did bulk spices, the inner box liners didn't have any information at all and the labeling was on the box. In that circumstance it's not practical to remove the 30-50lb filled liner from the box, it would rip to shreds, so it was practical to only label the outside of the box.
At minimum the best by or expiration date is required on the exterior, the lot code can be on an inner pouch. Had a product very similar that was produced by a co-man and this was the same process. There was also a general code that referenced what the product was on the inner pouch as an identifier.