New California AB660 Food Date Labeling Rule for B2B Product

We sell ingredients to other businesses for use in their manufacturing process. Our products are not for retail sale. We do not use best by or use by dates on most of our products, unless requested by a customer. 

I'm trying to interpret the new CA rule for Food Date Labeling. If we currently don't put best by or use by dates on our product, and the new regulation states, "when labeling products", does this mean we are (1) now required to add "Best if used by" or "Use by" to product or (2) exempt from rule as we don't include dates on product in the first place?

Appreciate your interpretation of new rule. Thank you!

From the CDFA - Inspection Services - Food Date Labeling:

"AB 660 (Irwin) requires food manufacturers to use uniform terminology when labeling products with "quality" or "safety" dates and bans the use of consumer-facing "sell-by" dates. Starting July 1, 2026, this bill prohibits the sale of any food item (except eggs and infant formula) for human consumption in California that is not labeled for quality using the terms "best if used by" or "best if frozen by" or labeled for food safety using the terms "use by" or "use or freeze by."

I think that entire law only applies to items offered to consumers, either through a retail store or through your own online sales.  Note lots of use of "consumer-facing" and "labeling food items intended for human consumption" within the actual bill.  Your B2B items aren't being sold as consumer facing or intended for human consumption but intended as an ingredient in further manufacturing.

I agree with jfrey123. You don't need to add a use-by-date on your products. To stay on the safe side - for customers that request use-by-dates - I would use the verbiage the used in the new CA bill.