6 replies to this topic

[christianlora_]

Hi everyone,

I'm a third-year Food Science and Technology student in Italy, trying to understand how label artwork approval actually works in practice - not how the regulation says it should. My coursework covers Reg. 1169/2011 in detail but says nothing about who does what inside a company.

What I'm trying to understand: recipe/labelling software generates a compliant ingredient list and nutrition table from formulation data. I don't know if this actually happens in practice, but I'd guess that once a design agency turns that into print-ready artwork, things could change along the way - type size, allergen emphasis, whether mandatory information stays in the same field of vision. Does it?

Questions for people who do this for a living:

1. In your organisation, who signs off the final print-ready PDF before it goes to press - QA, regulatory, marketing, technical manager? One person or a chain? And - is your company the brand owner, or do you produce/print under someone else's brand (private label, co-pack, contract manufacturing)? I'm asking because I suspect the answer to "who checks" is completely different depending on which one you are.
2. Roughly how long does checking one artwork take (say, a straightforward reprint with no formulation changes), and what do you check it against - an internal checklist, a software tool, an external consultant?
3. Has an error ever made it all the way onto printed packaging? If so, did it come from the underlying formulation data, or was it introduced later, during the artwork/typesetting stage? What did it cost to fix - reprint, rework, recall?
4. If you use an external labelling consultant: what do you send them, and what do you still check yourselves?

Any answer helps, even a short one. Thanks.

[TimG]

1. This has been different in each organization I've been a part of. My current organization has our own brands as well as many private label brands. The V.P. of Marketing signs off on labels, and depending on if it's private label the salesman for that customer is working with the brand owner to get the labels in order before the VP's final sign off. As QA director I have also kicked some back for small things (organic honey just listing 'honey' as the ingredient, etc.)
2. Few days/weeks for our brand and could be months for private labels (lots of back and forth with some of them). There is nothing to 'check it against' really. There is a checklist to make sure all of the main USDA/FDA requirements are hit
3. Yes. Once where we had to discard labels (before my time) but most are not critical errors. We had our organic company have us change how their 'certified by' appeared on the labels, and then change it again 6 mo's later. Obviously everyone pushed back and they only required the new rules to go into place on any future label plates.
4. We don't. But in the previous facility I worked (global company) the Global V.P of regulatory compliance had final say and he had a regulatory law group who reviewed any label change/creations before they were finalized.

[MDDF]

It's different everywhere, but here:

 

• In your organisation, who signs off the final print-ready PDF before it goes to press - QA, regulatory, marketing, technical manager? Technical Director, the head of QA/Regulatory
• One person or a chain? One Person
• And - is your company the brand owner, or do you produce/print under someone else's brand (private label, co-pack, contract manufacturing)?  Both
• Roughly how long does checking one artwork take (say, a straightforward reprint with no formulation changes), and what do you check it against - an internal checklist, a software tool, an external consultant?  Depends on the customer, number of labels, etc.   Can take a few hours, can takes weeks of back and forth.   We don't use software, other than to calculate for nutrition panels.   We do have an internal form but it's more to document new products, etc.   I don't usually use it for a new label.   Sometimes, just depends.
• Has an error ever made it all the way onto printed packaging? If so, did it come from the underlying formulation data, or was it introduced later, during the artwork/typesetting stage? What did it cost to fix - reprint, rework, recall?  Nothing major that I can recall.   We print every order, so cost to repair would be virtually nil, we don't have stock of labels on site.
• If you use an external labelling consultant: what do you send them, and what do you still check yourselves?  Never had a consultant for labeling.

Edited by MDaleDDF, 10 August 2026 - 01:41 PM.

[christianlora_]

Thank you both, this is exactly the kind of detail the regulation doesn't tell you.

Two things I hadn't expected: that marketing can be the one signing off rather than QA, and that in some setups there is nothing to check the artwork against beyond an internal checklist.

MDaleDDF's point is the one that stuck with me: "we print every order, we don't have stock of labels on site, so cost to repair would be virtually nil." That reframes the whole question for me - the cost of a labelling mistake seems to depend less on what you produce and more on how the packaging is printed.

So one follow-up, for anyone reading:

• Do you print labels and packaging to order, or do you hold pre-printed stock (film, cartons, sleeves) that would have to be scrapped if something changed?
• When a mistake did happen, did it come from the formulation data itself, or was it introduced later, when the artwork was laid out?

And if anyone here works under EU Reg. 1169/2011 rather than USDA/FDA, I'd be curious whether the process looks different. Italy raised the penalties for labelling breaches in May (up to 3% of annual turnover for some articles), and I'm wondering whether that changed anything in practice or whether it just sits in the background.

Thanks again for taking the time.

Edited by christianlora_, 10 August 2026 - 02:21 PM.

[G M]

Hi everyone,

I'm a third-year Food Science and Technology student in Italy, trying to understand how label artwork approval actually works in practice - not how the regulation says it should. My coursework covers Reg. 1169/2011 in detail but says nothing about who does what inside a company.

What I'm trying to understand: recipe/labelling software generates a compliant ingredient list and nutrition table from formulation data. I don't know if this actually happens in practice, but I'd guess that once a design agency turns that into print-ready artwork, things could change along the way - type size, allergen emphasis, whether mandatory information stays in the same field of vision. Does it?

Questions for people who do this for a living:

1. In your organisation, who signs off the final print-ready PDF before it goes to press - QA, regulatory, marketing, technical manager? One person or a chain? And - is your company the brand owner, or do you produce/print under someone else's brand (private label, co-pack, contract manufacturing)? I'm asking because I suspect the answer to "who checks" is completely different depending on which one you are.
2. Roughly how long does checking one artwork take (say, a straightforward reprint with no formulation changes), and what do you check it against - an internal checklist, a software tool, an external consultant?
3. Has an error ever made it all the way onto printed packaging? If so, did it come from the underlying formulation data, or was it introduced later, during the artwork/typesetting stage? What did it cost to fix - reprint, rework, recall?
4. If you use an external labelling consultant: what do you send them, and what do you still check yourselves?

Any answer helps, even a short one. Thanks.

 

1. a chain of approvals going through marketing/sales, ending with the regulatory division of the food safety and quality team.  

2. it can vary wildly depending on the claims, design complexity, and involvement of a customer or co-branding partner, I've seen some take months and others just a couple days.

3. yes, we've had errors make it to packaging.  usually they're on the reviewers becoming 'blind' to design elements or information they've looked at too many times, but on a few occasions packaging material was purchased before final approvals were reached in an effort to get product to market ASAP because making the packaging material can take longer than some approval processes and these had to be scrapped without ever being used.

4. n/a

[GMO]

UK here but the last time I worked on this in anger we were in the EU and we still operate to EU law here. I will answer for a small company then answer for a large one I was working in till about 3 years ago.

 

Small company:

1. In your organisation, who signs off the final print-ready PDF before it goes to press - QA, regulatory, marketing, technical manager? One person or a chain? And - is your company the brand owner, or do you produce/print under someone else's brand (private label, co-pack, contract manufacturing)? I'm asking because I suspect the answer to "who checks" is completely different depending on which one you are. We produced both own label and for retailers under their label. We actually had the same system for both. We had a combination of people who checked every label and every version. FSQ / QA / Technical people and Marketing. The latter were for the copy rather than technical information. We also had independence from whoever had written the spec. I.e. the same person didn't write the spec AND check the artwork. As the artwork approval also was checking against spec data, there was a small chance of picking up an error in both and also there was a bigger chance the person would have known their inputs were "right" so assumed the outputs would be too. Human nature. We also had several trained artwork approvers across the team to reduce workload on any one individual and so we could have independence between versions.
2. Roughly how long does checking one artwork take (say, a straightforward reprint with no formulation changes), and what do you check it against - an internal checklist, a software tool, an external consultant? Both an internal checklist and an output of the spec; timing, ça dépend. Truly just "checking" a pre made artwork against the spec outputs and in internal checklist? Experienced people with a "typical" product they're familiar with, could be as little as 10 minutes. Inexperienced or new product, could be 30 mins. That's per person obviously. If you have multiple version numbers then checking, making changes etc, rechecking, that could take weeks but the time isn't the checking per se but the time taken by the artwork house to correct errors.
3. Has an error ever made it all the way onto printed packaging? If so, did it come from the underlying formulation data, or was it introduced later, during the artwork/typesetting stage? What did it cost to fix - reprint, rework, recall? In this business, yes. It was introduced at artwork stage, correct on the spec, it was a very small error but important so easy to miss. It cost us nothing because the error was actually at the retailer not us but we were harder on ourselves internally as we should have spotted it.
4. If you use an external labelling consultant: what do you send them, and what do you still check yourselves? We checked everything ourselves. I'd never use external consultants as the only check. Retailers do use Ashbury a lot over here. Problem is that they don't truly bear the responsibility of error in the same way the manufacturer would.

​The differences in a large company were bizarre. It was, strangely, much less robust and clear. Who checked artwork wasn't obvious to those at the sharp end of production and when things did go wrong (and they did) they were much less transparent about the causes. When pushed they didn't have the segregation of duties I would expect, nor process robustness. It really surprised me. Obviously the consequences were much bigger. The recall I'm thinking of ran to several hundred thousand.

[Tony-C]

Hi christianlora_,

 

Welcome to the IFSQN forums.

 

 

Similar to the previous posts by G M & GMO, I have an artwork approval form and the artwork is signed off by a number of responsible authorised and qualified/trained people from purchasing, sales/marketing, operations, NPD, and QA/technical.

For a rush job it could be done in a few hours but would typically take a few days to go round.

I can only remember one error which wasn't significant enough to pull the printed labels.

I would only use a consultant if it was someone I knew and was 100% confident in.

 

Kind regards,

 

Tony