Food Label News
November 2018 — Volume 18, Number 11

Feeling grateful as we complete our 25th year. Tax and taxi. Joy and job. A few letters can significantly alter a word's meaning as we see with labels and labeling in this month's feature article. Read on to learn how a manufacturer working with a major national grocery chain submitted food labels in record time to secure an order after six months of work. As always, we're thankful for you, our readers and clients. 

In this issue:



Karen C. Duester, President, Food Consulting Company

P.S. We're expanding our small virtual team with an entrepreneurial leader who will drive a new business unit for Food Consulting Company. Interested?


Feature Article

Is there really any difference between "label" and "labeling"? According to the Federal Food, Drug & Cosmetic Act, the answer is yes. 

  • Label is defined as the "written printed or graphic material on the immediate package." Most food labels are regulated by FDA, unless it's for a USDA regulated product. 
  • Labeling means "all labels and other written, printed, or graphic matters upon any article or any of its containers or wrappers, or accompanying such article." In other words, labeling encompasses both the label and all accompanying material on or near the package, including material at the point of purchase. FDA/USDA and FTC share responsibility for food labeling.

Let's consider some examples:

Hang tag - This is part of the label and it is also labeling. A hang tag must comply with all FDA/USDA requirements and if there is any issue with non-compliance, FDA/USDA and/or FTC will step in to remedy the situation. 

Shelf tag - This is accompanying material at the point of purchase and must comply with FDA/USDA regulations. Non-compliance issues would be handled by FDA/USDA and/or FTC. 

Print or TV advertising - While any advertising claims must comply with FDA/USDA requirements as defined in the Code of Federal Regulations, non-compliance issues are policed by FTC.

Bullseye: FDA/USDA generally has authority over labels and labeling, though when false claims are made in advertising or promotional material, FTC will get involved. In general, FTC levies harsher penalties and bigger fines. This underscores the importance of companies to follow all requirements for labels, labeling and promotional material to ensure communication is truthful and not misleading.

Food Label Community
  • Labeling folate
  • %DV of protein calculation 
  • Made with honey claim 
  • Contains __% or less statements 
  • Ascorbic acid (antioxidant) 


Reader Q+A
Q. I have a sauce that I want to sell in bulk to foodservice. Do I have to have a Nutrition Facts label on each container? 
— J.M., California, Food Manufacturer
A. Products sold to foodservice may omit the Nutrition Facts label provided the product will be further processed (not sold in packaging) and a nutrient content or health claim is not made on the label or labeling.


Client Comments

"Food Consulting Company is exceptionally responsive - you always get a prompt reply. They appreciate that you are a customer and take care of you. They work fast, accurately; tell you clearly what they will do and deliver on time every time. No hassles. No surprises. Working with them is worry-free."
— Kawal Oberoi, CEO, Dishaka Gourmet Imports. 


Food Consulting Company
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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.

Food Label News, now in its 18th year, is a monthly e-newsletter reaching over 10,000 subscribers around the world. We cover news and insights about what matters most in food labels and welcome your question for a future Reader Q+A.



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