Food Label News - July 2010

Volume 11, Number 7 - July 2010

Hello from Food Label News. Happy 4th of July to all our U.S. readers and greetings to others worldwide. Count on us to bring you what matters in food labeling. For example, the important topic of claim support is one that perplexes many of our clients. We also include a focus on database nutrition analysis and use of the word "natural" – two areas for which we provide insight daily.

In this issue you'll find:

Claims Support: What's Important for Food Labels
Due Diligence with Database Nutrition Analysis
Reader Q&A: "Natural" or Not?
Helpful links to keep you current

Karen C. Duester, President

"Food Consulting Company has consistently provided us with reliable, usable label and regulatory information, quickly, and always with the patience we look for in a quality service provider. Every month this service is supported with valuable information in the email newsletter that allows us to plan ahead."

– Phil Brooks,
Jones Soda

Claims Support: What's Important for Food Labels

Today’s nutrition-conscious consumers read your labels diligently for helpful information to make informed food choices. Claims about a product's health benefits can make the difference between a consumer choosing your product or a competitor's. What does it take to make truthful claims that both entice consumers and stand-up to the scrutiny of FDA (who oversees food labels) and FTC (who oversees advertising)?

As outlined in our recently published Regulatory Guide, claims including nutrient content claims, statements of fact, health claims, structure/function claims, and dietary guidance statements - require specific substantiation. Some claims require clinical trials and others can be supported by significant scientific agreement or lab analysis. In general, these guidelines apply:

Nutrient Content Claims & Statements of Fact – lab or database analysis
Health Claims & Structure/Function Claims – significant scientific agreement; clinical trials may be required
Dietary Guidance Statements – significant scientific agreement

For more information on FDA and FTC policies on substantiation and enforcement for food label claims, see Keeping You Current column at right.

Keeping You Current

FDA guidance on the review and evaluation of health claims

FDA guidance on substantiation for dietary supplement claims

FTC enforcement policy on food advertising

FTC industry guide for dietary supplement advertising

FDA issues warning letters for inaccurate claims, incomplete ingredient statements, and other misbranded food issues

FTC objects to immunity-related claims for Rice Krispies

Dietary guidelines advisory committee releases report

Qualified health claims survive court challenge on first amendment rights

Center for Disease Control seeks grant applications to help reduce sodium intake in the U.S.


	"Silliker Nutrient and Health Claims U.S. Regulatory Guide," cooperatively developed by Food Consulting Company and Silliker, Inc., offers product developers insights into which types of claims are best suited to a product's nutritional attributes and marketing objectives. You can find and download the complete guide here.

Due Diligence with Database Nutrition Analysis

Food Consulting Company originally authored a publication with the above title in 2007 for the Nutrition Study Group of the National Restaurant Association. This handbook, updated in 2010, instructs about the seven steps to ensure that the results of your database analysis will stand up to the scrutiny of government, media, consumers and competitors. Several tips:

It's important to evaluate your suppliers' specification sheets to ensure that they include all of the nutrients for which you will be analyzing.
It's imperative to make processing adjustments for moisture loss that occurs during cooking and baking.
While obvious, do the "common sense" check at the end of your analysis. For example, check to see if there is a misplaced decimal in a slice of Boston cream pie that appears to contain only 45.9 calories.

ESHA Research, makers of the Genesis R&D SQL^TMsoftware, distributes this handbook to their customers. Download a copy here.


	While you can get good results with database analysis and it's more cost-effective than lab analysis, the process and interpreting the results is not as easy as it appears on the surface. Watch for the various nuances that may apply to your product.

Reader Q&A

Find answers to our readers' questions or send us your question for an upcoming issue.

Q.	I am using all natural ingredients in a package. It says it has vanillin in it. I think vanillin is a compound, so does that mean I cannot say "all natural ingredients"? − D.H., Package Designer, Michigan
A.	Vanillin is typically a synthetically-derived compound (artificial flavor). FDA does not allow a "natural" claim for products that contain artificial flavors, added colors (from any source), or chemical preservatives. See June 2008 Food Label News for further discussion about "natural" claims on FDA, USDA and CFIA-regulated products. More reader questions.

At Your Service

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With over 1,000 clients worldwide, Food Consulting Company's services are ideal for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. Contact Us for more information about your food labeling needs.

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