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Volume 17, Number
5 -
May 2017
Spring has sprung.
Questions about ingredient labeling continue to pop up.
This month we review the regulations surrounding the use
of composite ingredient statements and why some food
labelers take this approach.
The monthly Reader Q&A
helps a manufacturer understand the timing of using up
existing labels and the Reader Favorite revisits
required restaurant menu labeling – which now has an
extended compliance date of May 7, 2018.
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In this issue you'll find:
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"We LOVE your newsletter. You do
a great job of compiling and
explaining relevant industry
information."
–
Meredith Williams
Clabber Girl Corporation
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Karen C. Duester, President
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More About Ingredient Labeling:
Expanded vs. Composite Lists
Last month we covered when ingredients can
be combined in the ingredient statement. In
short, ingredients with established common
or usual names or standards of identity may
be grouped by a single ingredient name
followed by sub-ingredients in parentheses.
For example: vegetable oil spread (water,
soybean oil, palm kernel oil, salt, soy
lecithin). This is the expanded approach.
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There is another option for ingredient
listing that is also compliant. Instead of
declaring the common or usual name, the
sub-ingredients may be incorporated into the
overall ingredient listing in descending
order of predominance. If any of those same
ingredients are elsewhere in the formula,
the sum (the "composite") must be used to
determine the order of predominance in the
finished product's ingredient statement.
Using the above example, the sub-ingredients
in the vegetable oil spread (water, soybean
oil, palm kernel oil, salt, soy lecithin)
can be combined with identical ingredients in the
formula and listed separately in descending
order in the finished product's ingredient
statement, without the term "vegetable oil
spread." |
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There are several advantages to using the
composite approach:
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A shortened ingredient statement may be
easier for consumers to understand.
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Combining the same ingredients from multiple
sources may elevate key ingredients in the
ingredient list, which could provide a
benefit for marketing.
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Combining identical ingredients from
multiple sources makes it more difficult for
competitors to replicate the formula and
enables a manufacturer to keep its recipes
proprietary.
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For the specific FDA requirements about
composite ingredients in an Ingredient
Statement, see
21CFR101.4.
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The composite method requires
manufacturers to have information about
sub-ingredients. In the vegetable oil spread
example, the percentage amounts for each
sub-ingredient will be necessary to
determine where each ingredient fits in the
overall ingredient statement. However,
manufacturers may not know the percent breakdown of
sub-ingredients – a limiting factor in using
this approach. While ingredient suppliers
will have the information for using the
composite approach, they may be reluctant to
share the details to protect their own
formulas. Sometimes it’s possible to get a
range formula from an ingredient supplier
that provides enough information to ensure
that the ingredients in the finished food
are listed in the correct descending order.
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What's
News
in the Food Label Community
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Reader Q&A
Find answers to our readers' questions or send us your question for an upcoming issue.
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Q.
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When my supplier changes an
ingredient in a raw material,
how long can I use existing
inventory of labels and be in
compliance?
− J.D., Texas, Food
Manufacturer
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A.
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There is no phase-in or grace
period for labels to comply with
FDA labeling requirements. That
is, all ingredients must be
listed in descending order of
predominance in the final
product's ingredient statement.
If ingredients are changed, as
is the case with your situation,
the listing of ingredients on
the product's label must reflect
the exact raw materials in the
formula.
More Reader Q&As.
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What Matters in Food Labeling
Food Label News, now in its 17th year, is a monthly e-newsletter reaching over 10,000 subscribers around the world. We welcome your colleagues to subscribe for news and insights about food labels: www.foodlabels.com/subscribe
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Your Virtual Food Label Partner
Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling, and regulatory support for more than 1,500 clients worldwide.
Our guarantee: 100% regulatory compliance. Contact us for the help you need now.
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© 2017. Food Consulting Company, Del Mar, CA. All rights reserved.
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