USDA Label Approval for By-Products
My company makes cold cuts packing them into MAP trays. I got LPDS approval for them as they have special statements on labels.
Besides this, as by-product, ends and pieces (ends, slices out of spec) are also made, packing them into vacuum bag. No special statements or claim on these labels indeed.
That said, can I use the label approval of the MAP trays to generic approve ends and pieces label?
I came up with a document which states what below:
"In reference to the labels approved by USDA (xxxxx,xxxxxx,xxxxxxx,xxxx) company Y is generically approving labels for its ends and pieces product lines.
These labels will feature only mandatory information.
Special claims and statements have been removed.
A copy of each product label is attached below."
What are your thoughts guys? Is the way I set this up good to go?
If you are not transferring the special claims and statements then there is no need to reference the previous LPDS approval (it doesn't hurt to reference it though). All that is required is to have Product Formulation, Processing Procedures, and a copy/sketch of the Final Label.
Simply fill out a FSIS Form 7234-1, and have it on file. No need for LPDS approval in this case since no claims are made.