Volume
8, Number 10 - October 2007
IN THIS ISSUE:
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About Food Consulting Company
"I want to thank you for the (full
label compliance) service you provided. The
report is detailed and answered all my
questions I needed. My graphic artist will
have no problem following the instructions
and you certainly made his life easier! The
work was done in the time frame promised and
we will definitely recommend your services."
~
Alfred Nasti
MIT Commodities
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Dear Readers,
Questions to Food Consulting Company tell us
trans fat labeling is still challenging. Food
Label News has provided several
use-now-tips in the 2007 issues. Choose the following links to
refresh understanding of trans fat labeling:
Trans Fat on Nutrition
Labels Still Puzzles,
Trans Fat Labeling
or
Definition of Trans Fat
Free.
Peruse the
Food Label News archive to find more helpful labeling
information. |
Q. Is FDA
approval of food labels required? If yes, does
Food Consulting Company include this step in my
label order?
T. T., Start-up, Washington, DC
A. FDA
does not require or provide a service for the
Agency's approval of food labels. However,
labelers must comply fully with the labeling
regulations on their own or through the help of
their choice. Food Consulting Company helps you
produce
100% FDA compliant labels with
Full Label Compliance
and
Label Compliance Review. Read more:
Reader Q&A page.
Submit a question
for Reader Q&A (no charge). |
FDA Reminds on Food Labels Sugar Free Claim
In a September 2007 Dear Manufacturer Letter
Regarding Sugar Free Claims, FDA states concern
about products that contain claims regarding the
absence of sugar (e.g., sugar free) but that
fail to bear the required disclaimer statement
when the foods are not "low" or "reduced in"
calories or fail to bear the disclaimer
in the manner specified in the regulations. Products labeled as
"sugar free" but that are not low or reduced in
calories according to FDA definition, are
required to disclose this fact with "not a
reduced calorie food," "not a low calorie food,"
or "not for weight control."
Enforcement of regulations regarding "sugar
free" labeling is an FDA priority. FDA stated
the Agency intends to take action against
products that claim the absence of sugar but
that fail to fully comply with the regulation
that defines "sugar free."
See
FDA letter to
manufacturers.
Commentary: Before claiming a food is
sugar free, a labeler must determine several
related characteristics of the food including
calories per serving and if the portion fits FDA
definition for small serving, main dish, or
meal.
Food Consulting Company understands the desire
of food companies to use label claims to promote
product appeal and increase sales. Choose
Full Label Compliance
or
Label Compliance Review
to get expert and timely help.
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About Food Labels Allergen Warning
Based on questions received by Food Consulting
Company in recent weeks, confusion exists
regarding allergen advisory statements when
foods are processed with shared equipment or in
a shared facility. At this time the Food
Allergen Labeling and Consumer Protection Act (FALCPA)
does not require the use of advisory labeling to
describe the potential presence of unintentional
ingredients resulting from the food
manufacturing process. Labelers may voluntarily
use an advisory statement as long as it is
truthful and not misleading; however FDA has
stated that advisory labeling such as "may
contain [allergen]" should not be used as a
substitute for adherence to current Good
Manufacturing Practices.
FALCPA does require products with ingredients
that contain one of the "big eight" food
allergens (milk, egg, fish, Crustacean
shellfish, tree nuts, wheat, peanuts, soybeans)
to indicate this by listing the common or usual
name of the major food allergen in the
ingredient panel.
Commentary: To fully understand allergen
labeling requirements, labelers must carefully
read
Food Allergen Labeling and
Consumer Protection Act of 2004 and
FDA Guidance-Questions and
Answers Regarding Food Allergens.
Your labels will be allergen compliant when you
order Food Consulting Company's
Ingredient Statement
service,
Full Label Compliance
or
Label Compliance Review.
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Food Labels Health Claims & 2008
Appropriations
In September 2007, Food Label News reported that
a U.S. House of Representatives 2008
appropriations bill includes the statement "No
funds in this Act may be used to authorize
qualified health claims for conventional foods."
Since then Food Consulting Company learned from
Center for Science in the Public Interest (CSPI),
a supporter of the measure, that if the final
bill contains the measure and is signed into
law, "FDA will not have to take any affirmative
action. Theoretically, the Agency could announce
in a short Federal Register notice that it is no
longer accepting requests for qualified health
claims for foods because of the appropriations
restriction."
Also from CSPI, supporters of the measure assert
"the results of consumer research conducted by
both the FDA and the International Food
Information Council (IFIC) indicate that
disclaimers do not cure the deception created by
claims based on emerging science."
To become law, the measure must be part of the
final appropriations bill that the president
signs. As of September 30, 2007, the
appropriations bill is stalled in the U.S.
Senate.
See
Food Label News September
2007.
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At Your Service: Plan now for 2008
regulatory support.
With Food Consulting Company's
FDA Regulatory Support
in 2008, labelers will quickly move past
technical information roadblocks that can slow
label completion. Choose a plan that matches
your needs.
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©
2007,
Food Consulting Company.
www.foodlabels.com.
All rights reserved.
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