Labeling refrigerated or frozen products

Hi, 

Scenario: A manufacturer will produce a RTE side dish for a customer that will create food packs boxes to sell and distribute frozen. The question is: Could the manufacturer label each container "KEEP FROZEN" (exp 365 days after production) but ship the product refrigerated to the customer so this one will freeze the product as soon as received (24 hrs.)?

or Could the manufacturer pass by with a label outside the box that would have a shelf life as refrigerated then said freeze by DATE. "KEEP REFRIGERATED, FREEZE BY MM-DD-YY"?

From what I know, I thought if the specs of the product will be to keep frozen, the manufacturer needs to ship the product FROZEN if the specs said Keep Refrigerated so it will ship refrigerated.

I would like some feedback on labeling compliance regarding this situation. if you have any FDA or USDA link I appreciate if you share that.

Thank you so much.

I'm surprised there hasn't been a reply to this, but here: https://www.fsis.usd...-product-dating

Long story short, there are no requirements for dates on products except for baby food.  However, customers will complain if the dates don't lead to safe food.  It would be best to contact a food microbiologist to have them conduct a shelf life study with the intended lengths of time that the product will be shipped refrigerated before it would need to be frozen.

After the Freeze By date is selected, the product should have another shelf life study done with the product having been refrigerated that long and then frozen to determine its final expiration date.

These are all really quality metrics, and not food safety metrics.  This shouldn't be done with foods that must be shipped frozen or have very short refrigerated shelf lives.