Volume
6, Number 11 - November 2005
IN THIS ISSUE:
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About Food Consulting Company
"I would like to thank you for your prompt
and detailed response of the projects that
my company sent to you. We will definitely
be utilizing the broad array of services
that you provide in the near and distant
future. Thanks for everything that you've
done."
– Jeremy Hibbs
Byesville Aseptics LLC
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Greetings! This issue of Food Label News
marks the beginning of the sixth year of
publication and free distribution to clients and
guest subscribers. Food Consulting Company is
proud to report that Food Label News has been
delivered each month for 60 months straight! As
with this newsletter, you can always count on
Food Consulting Company for accurate, on-time
project
completion, and expert guidance on applying FDA
regulations. Visit Food Consulting Company at
www.foodlabels.com. |
Food Label Allergen Questions
Answered
In a Food Label News, October 2005 special
edition, Food Consulting Company reported on
FDA's October 5, 2005, Final Guidance entitled
"Questions and Answers Regarding Food Allergens,
including the Food Allergen Labeling and
Consumer Protection Act (FALCPA) of 2004." Food
Consulting Company was answering many questions
about allergen labeling at the time and so
promised to answer readers' allergen questions
in the November issue of Food Label News.
According to FALCPA, all packaged foods
regulated under the Federal Food, Drug, and
Cosmetic Act that are labeled on or after
January 1, 2006, must comply with the new
allergen regulations.
Food Consulting Company found readers are
interested in the following points:
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Products with labels that do not comply with
FALCPA that were labeled prior to
January 1, 2006, can remain in the marketplace.
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FALCPA does not require the "contains"
statement as long as the ingredient
statement uses the common or usual name of
the allergens present. When a "contains"
statement is used, it must include all of
the Big 8 allergens that are present in the
product and be equal in print size and
prominence to the ingredient statement.
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FALCPA does not require advisory labeling,
such as "manfactured in a facility that also
processes [name of allergens]," however
companies may use it voluntarily as a
statement of fact.
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FDA discourages the use of "may contain [name of
allergens]" labeling, and says that such labeling
should not be used as a substitute for adherence
to current Good Manufacturing Practices.
Read FDA Q&A Guidance on Allergen Labeling and
access FALCPA:
http://www.cfsan.fda.gov/~dms/alrguid.html
Find more information on 2006 compliance
requirements for food labels:
www.foodlabels.com/2006
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Misleading Food Labels / Label Claims Targeted
On October 24, 2005, FDA sent notices to 29
companies warning them to stop making unproven
treatment/prevention claims, for cherries and
other fruits, on product labels and web sites.
FDA
warns the companies to take prompt corrective
action or face FDA enforcement action that could
include seizure of products, injunctions or
criminal sanctions.
Read FDA press release and
access warning letters:
http://www.fda.gov/bbs/topics/news/2005/new01246.html
On October 27, 2005, a consumer watch group,
Center for Science in the Public Interest (CSPI)
released a press statement that criticizes FDA
for failing to stop food labeling that deceives
consumers about a product's healthfulness. CSPI
says FDA's inaction has been a signal to food
manufacturers to use more deceptive claims. The
release notes that in the absence of adequate
FDA oversight and enforcement, CSPI acts
independently, through legal action, to get
companies
to cease deceptive labeling.
Read CSPI press release:
http://www.cspinet.org/new/200510272.html
Commentary: Food Consulting Company
believes that the use of misleading claims and
product information in labeling and marketing is
wrong and a poor business choice. Food
Consulting Company guarantees that all label
components and regulatory advice provided by
Food Consulting Company on clients' behalf are
100% compliant with current FDA regulations.
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Annual Support Plans
for Food Labels Regulatory Help
Beginning November 1, 2005, Food Consulting
Company is offering annual support plans for
food labeling and regulatory help. The plans are
prepaid arrangements for food labeling advisory
help over a 12-month period; a basic and
comprehensive plan is offered. The two plans
differ by the type and volume of help a company
anticipates needing in the upcoming period. The
Ongoing Regulatory Support Plans are described on
the Services page at
www.foodlabels.com.
Companies can begin service immediately or at
any later date by placing an online order.
Companies subscribing to the support plans
before January 1, 2006, can use the service from
the date of payment and for the full 12 months
beginning January 1, 2006.
As always, companies can submit questions for
Regulatory Research on a per incident basis.
Commentary: Both small and large
companies, with and without dedicated food
labeling staff can benefit by the plans. Because
Food Consulting Company is well versed in FDA
food label regulations and keenly able to work
back-and-forth through the Code of Federal
Regulations, final rules and FDA guidance, the Company can save
all sizes and types of companies many hours of
research time and the related costs.
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FYI: FDA is
holding a public meeting November 17, 2005, on
"Assessing Consumer Perceptions of Health
Claims." Research presented will be used to plan
future study on the effect of health claims on
consumer perceptions and behaviors. |
Get more from
Food Label News: Send
topic suggestions.
Need help now? Submit a question for Regulatory
Research or subscribe to an Ongoing Regulatory Support Plan at
www.foodlabels.com/orders.
Please share this newsletter in its entirety, including subscription and copyright information.
© Food Consulting Company, 2005
13724 Recuerdo Drive, Del Mar, CA 92014 USA
tel 800-793-2844 or 858-793-4658
fax 800-522-3545 or 858-712-3323
www.foodlabels.com |
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