Navigating Food Labeling Regulations | A Compliance Checklist
In order to get your food or beverage product market-ready, you have to be compliant with food labeling regulations. And like every industry, consumable products have multiple layers of compliance. There are federal regulations, state regulations, and certain additional regulations for specific consumable commodities (i.e. cannabis products and pet foods). Wherefour is prepared to help you navigate your specific regulatory landscape starting with this checklist of essential food label components.
GENERAL LABEL INFORMATION
The placement of the label itself, the name of the product (aka “the statement of identity”), the name & address of the manufacturer and/or distributor, the country of origin (if imported), the size, font, color and placement of logos and artwork — all of these specifications are regulated and must be within the margins of compliance. The main product label (the principal display panel or PDP) is specifically regulated by the FDA. There are allowable variations within these categories to account for size of product, size of packaging and other factors, so make sure you know what rules are in place.
NET QUANTITY OF CONTENTS
Compliant labels must clearly and accurately list the amount of product contained in the package. This information allows consumers to compare value and size among available brands. The quantity must be listed in both U.S. standard terms and metric terms (such as ounces and grams). Again, size, positioning and style of information is regulated, so be sure to follow the established rules. And, measurements vary for solid vs. liquid food products too!
INGREDIENT LIST
The ingredient list is pretty self-explanatory, but it too is regulated. Ingredients must appear in descending order and must be conspicuous and legible. Common names of ingredients must be listed (for example, “sugar” instead of “sucrose”). Regulations vary on the inclusion of trace or incidental amounts of some additives, so make sure you are familiar with regulations pertaining to your formulas. And on the topic of food additives, it’s a whole can of worms! (Pun intended.) Approved additives must be listed with the common name AND the function of the ingredient, such as “Tocopherols” and “as a preservative.”
NUTRITION FACTS PANEL
Usually in close proximity to the ingredient list, this standardized “NUTRITION FACTS” box contains all pertinent product info such as serving size, calories, macronutrients, vitamins and minerals. This is what every grocery shopper looks at consciously or unconsciously to gauge things like “Am I eating enough fiber?” and “How much of a certain daily allowance am I consuming?” In order to calculate these values, manufacturers must seek analysis from independent laboratories. Trade associations, trade publications, and colleges and universities are great resources for finding the right lab in your specific market sector.
ALLERGEN DECLARATIONS
Declaring the inclusion of or possible exposure to the eight major food allergens is essential for public health. Milk, egg, fish, shellfish, tree nuts, wheat, peanuts and soybeans are considered the “major food allergens” and account for 90% of all food allergies in the United States. Depending on the product and the ingredient in question, there is joint oversight by the FDA and the USDA in labeling requirements, so check with your certifying agencies.
FOOD PRODUCT DATING
Although not regulated by the FDA, including an “expiration date” or a “best before” date on your product label goes a long way to building confidence among consumers and retailers. This information can be determined according to specific ingredients, storage protocol and packaging methods. Generally, the same lab that helps you to calculate your nutrition facts can aid in the determination of product dating, so lean on your established partnerships to label your products thoroughly. [NOTE: The exception to this rule is infant formula. Infant formula product dating is required by Federal regulations.]
Navigating food label regulations accomplishes three main goals: achieving governmental compliance, prioritizing consumer safety, and encouraging conscious healthy consumption. Brand recognition and trust are built on the shelf and on the plate, so invest in both the product and its label to keep consumers happy and healthy.
Familiarize yourself with the FDA’s “A Food Labeling Guide: Guidance for Industry" to learn about all the special provisions, variations and exemptions. And for guidance on organic certification, see the USDA’s “Labeling Organic Products” resources.
HOW AN ERP PARTNER OFFERS BUILT-IN COMPLIANCE
Ensuring product label compliance is only part of the regulatory picture. Running your business with the help of an ERP solution sets you up for regulatory compliance every day, everywhere. Governing bodies (like the FDA, USDA, NOP and Ecocert, to name a few) all require operational inspections and audits to approve products. These agencies inspect the entire manufacturing workflow, from raw ingredients all the way to on-the-shelf packaged goods, so using an ERP platform to run your operation gives you an undeniable advantage. Traceability, document storage, data retention, financial integration and recall-readiness are built-in to manufacturing operations that use an ERP platform.
