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...INTOUCH...   Volume 4/Number 10  -  October 3, 2003
Monthly Updates on Government Action Affecting Food Labels

Brought to you by:  Food Consulting Company
Your source for food label help at www.foodlabels.com
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Greetings!  We think our clients and long-time readers might enjoy
knowing that Christine Barnes and her work as a virtual assistant for
Food Consulting Company was featured in the September 15, 2003,
issue of Business Week magazine. Many of you who have called
Food Consulting Company have talked with Chris and we are sure
you have found her to be friendly and helpful.  Kudos to Chris for
her contributions to meeting our clients' needs!


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Food Labels Claiming "Low Carbohydrate" are Not Allowed
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In one recent day, Food Consulting Company received five separate
inquiries regarding the use of nutrient content claims for carbohydrate
content.  In each case, the food labeler was advised that "low
carbohydrate" claims are not permitted.

FDA regulations for nutrient content claims (21CFR101.13) permit
labels to describe the level of certain nutrients or dietary substances
in a product using terms such as free, high, and low, or to compare
the level of a certain nutrient in one food to that of another food, using
terms such as more, reduced, and lite.  FDA has not established
values for carbohydrate claims; therefore, the term "low carbohydrate"
cannot be used on food labels to describe the carbohydrate content
of a food.

Food labelers may make an accurate quantitative statement (e.g.,
5g carbohydrate per serving) as a statement of fact, as long as the
statement does not characterize the nutrient level to describe any
amount of a nutrient present.

A statement such as "only 5g carbs" is an implied nutrient content
claim since the word *only* characterizes the level of carbohydrate as
being low; this claim is not allowed.

...INTOUCH... Comments: The definitions of allowed nutrient content
claims as provided in the regulations are summarized in the Food
Labeling Guide, available at http://www.cfsan.fda.gov/~dms/flg-6a.html
See Q&A #3 under the "claims" section of the Food Labeling Guide for
FDA's statement prohibiting the use of unapproved nutrient content
claims:  http://vm.cfsan.fda.gov/~dms/flg-6-1.html


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New Guide for Trans Fat on Nutrition Labels is Available
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FDA has published a Small Entity Compliance Guide titled "Food
Labeling: Trans Fatty Acids in Nutrition Labeling, Nutrient Content
Claims, and Health Claims".  The guide is intended to help small
businesses understand the final rule for trans fat labeling published
on July 11, 2003.

Access the guide: http://www.cfsan.fda.gov/~dms/transgui.html

.INTOUCH. Comments:  Food Consulting Company has already
begun incorporating trans fat label requirements into food labels for
clients.  We can help you determine a strategy for getting your nutrition
facts panels updated quickly and easily.
Place orders: http://www.foodlabels.com/https://safeco.net/foodlabels/orders.htm


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FDA Regulations for Claims on Food Labels are Explained
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In September, FDA's Center for Food Science and Nutrition published
three documents at the Center's web site that define and clarify claims
that can be made on conventional foods and dietary supplements.  The
documents and web addresses are:

Claims That Can Be Made for Conventional Foods and Dietary
Supplements http://www.cfsan.fda.gov/~dms/hclaims.html

Summary of Qualified Health Claims Permitted
http://www.cfsan.fda.gov/~dms/qhc-sum.html

Structure/Function Claims
http://www.cfsan.fda.gov/~dms/labstruc.html

.INTOUCH. Comments:  INTOUCH reported extensively on "claims"
in September 2003.
See INTOUCH archive:  http://www.foodlabels.com/newsletter.htm


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FYI: Both the "Dietary Guidelines for Americans" and the "Food Guide
Pyramid" are under review and revision to meet new science-based
nutritional standards.  The "Guidelines" and "Food Guide" are two federal
nutrition guides to improve overall health through proper nutrition.  The
releases of the final "Guidelines" and "Food Guide" are scheduled for 2005.

Read news releases on Dietary Guidelines for Americans:
http://www.hhs.gov/news/press/2003pres/20030811.html

Read news release on Food Guide Pyramid:
http://www.usda.gov/news/releases/2003/09/0308.htm

© Food Consulting Company, 2003.