Volume 7, Number 4 - April 2006

IN THIS ISSUE:

• Trans Fat on Nutrition Labels Can Be Tricky

• Uniform Warning Standards on Food Labels Pending

• FDA Published Guidance Documents List

• Service Tip: Glycemic Testing & Labeling

Welcome Readers,

Food Consulting Company can help you cross tedious food labeling steps off your To-Do list. We offer a full range of services including Glycemic Testing & Labeling (described in Service Tip), and we provide accurate answers and solutions to puzzling food labeling questions with an Ongoing Regulatory Support Plan.

Trans Fat on Nutrition Labels Can Be Tricky

Calls received by Food Consulting Company in February and March 2006, indicate that in many cases food labelers continue to be confused about trans fat reporting requirements. A common point of confusion is how to report trans fat within the Nutrition Facts panel when the trans fat value is 0.

The precise answer requires careful reading of the Code of Federal Regulations and depends on whether the label uses a "standard" Nutrition Facts panel as defined in the Code of Federal Regulations at (21CFR101.9(c), or a "simplified" Nutrition Facts panel as defined in the Code of Federal Regulations at (21CFR101.9(f). It also depends on other factors including:

• whether the product contains a reportable amount of total fat

• whether the "not a significant source" statement is used

• whether claims are made on the label or in labeling

See correct and incorrect examples of Nutrition Facts panels related to trans fat reporting at http://www.foodlabels.com/transfat.htm

Commentary: If you need help with trans fat reporting, contract with Food Consulting Company to prepare or review your Nutrition Facts with the Nutrition Facts Label service at www.foodlabels.com, or receive ready help for all food labeling questions by purchasing an Ongoing Regulatory Support Plan also at www.foodlabels.com. As always, we will answer client questions related to work completed within the past 90 days without additional charge.

Uniform Warning Standards on Food Labels Pending

On March 8, 2006, the U.S. House of Representatives passed bill H.R. 4167, to amend the Federal Food, Drug, and Cosmetic Act to allow FDA to establish uniform food safety warning standards. The bill as passed prohibits states and other political subdivisions from establishing or continuing any requirement regarding food that is not identical to specified Federal Food, Drug, and Cosmetic Act provisions, including those related to adulterated foods and unsafe food additives.

The bill has been referred to the U.S. Senate Committee on Health, Education, Labor, and Pensions.

Read the bill.

Commentary: Food Consulting Company believes that the bill as written would have minimal impact on existing food labels and would be viewed by food manufacturers as a good thing. The bill must be passed by the full U.S. Senate and signed by the President before becoming law.

FDA Published Guidance Documents List

The March 28, 2006, Federal Register announces the publication of FDA's annual comprehensive list of all guidance documents that are currently in use by the Agency. The documents describe the Agency's current thinking on regulatory issues under its jurisdiction and establish common understanding of regulatory issues among Agency staff, industry, and the public.

The list identifies 23 documents under the Food Labeling category.

See Federal Register announcement.

See Food Labeling guides list.

Commentary: Guidance documents can be a big help to food labelers at any stage of label development. New startup companies and others who are new to food labeling will find the first guidance "A Food Labeling Guide" to be very helpful. For more information on Guidance Documents see Food Label News, March 2006, www.foodlabels.com/newsletter.htm.

If your company has a product or service complementary to the services of Food Consulting Company and you would like to talk about featuring it in this newsletter, please send an email by clicking here.

© Food Consulting Company, 2006
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