2 replies to this topic

[krissykokoski]

My company's headquarters recently moved to a new city, same state.  Is there a set timeframe to get tall of our food labels changed to reflect the new city?

 

Thanks in advance!

[jcieslowski]

Well since no one has chimed in, I guess I'll take a shot.

I think the right answer is 'no'.  There's no timetable and that your address is required to be correct on all product in the marketplace.

https://www.ecfr.gov...A/section-101.5

 

Now, given this little bit: "The statement of the place of business shall include the street address, city, State, and ZIP code; however, the street address may be omitted if it is shown in a current city directory or telephone directory."

I THINK one could make an argument that there place of business is posted and publicly available and demonstrate (by showing you moved) that there was no deception or attempt to confuse the consumer.

 

I would certainly suggest having all of your mail forwarded.  If that's the case, the only thing that would be wrong from a consumer perspective is if they decided to physically go to the address, which is not a good indicator anyway because the listed address doesn't even have to be the place the food is manufactured.

So, round about way, I wouldn't worry about it, though I think you'll already be 'out of compliance' with the letter of the law (but not the intent).

[SHQuality]

Neither the FDA nor the USDA labelling rules give a specific grace period to keep using labels showing an old address after a move.

Instead, the standard is: the label must not be false or misleading, and it must meet the requirement to bear the firm’s “name and place of business.” If the address on-pack no longer identifies the firm’s place of business (and didn't relocated within a city for the which the street level address was already omitted), the product can be treated as misbranded. 

 

This should have been taken care of before the move, but since that is no longer a possibility, I would suggest updating everything ASAP (and forward mail as jcieslowski suggested).