10, Number 3 - March 2009
IN THIS ISSUE:
About Food Consulting Company
" I read every newsletter that you
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that apply to my small business. Thank you."
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Carriage House Creations
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I have seen
products with a Nutrient Content Claim (NCC)
stating "0 grams trans fat." I have not found
this claim to be one of the approved NCC claims.
Is the claim illegal or allowed?
Registered Dietitian, New Hampshire
grams trans fat per serving" is a factual
statement, not a defined nutrient content claim.
Submit a question
for Reader Q&A (no charge).
Food Labels Carb Claims - Report Issued
In January 2009, FDA issued an analysis report
titled "Experimental Study of Carbohydrate
Claims on Food Packages." The document outlines
results from a study conducted in March 2006
that was designed to evaluate carbohydrate
claims and disclosure statements in terms of
their effects on consumers’ understanding and
ability to make product judgments for healthy
dietary practices. The report does not mention
how or how soon the study findings will be used.
The historical base for the study is the
popularity of low carbohydrate diets in the
early part of this decade (2003-2004). Industry
began incorrectly using words such as "low,"
"reduced," or "free" on labels to describe
carbohydrate content; FDA told industry that
this is not allowed since the terms are Nutrient
Content Claims. In a March 2004 fact sheet on
carbohydrate, FDA stated the intent to initiate
rulemaking for carbohydrate content labeling.
Commentary: While labelers cannot use
terms regulated as Nutrient Content Claims to
describe carbohydrate content per serving, they
can use statements of fact on labels; see
Food Label News
Net carbohydrate statements that are truthful
and not misleading can also be used; see Food
The articles are helpful to labelers who want to
appeal to the carbohydrate-conscious consumer.
Additional articles on carb labeling are:
Food Labels Health Claims Update
In January 2009, FDA issued "Guidance for
Industry Evidence-Based Review System for the
Scientific Evaluation of Health Claims." This
document replaces a draft version issued in July
The guidance represents the Agency's current
for evaluating the scientific evidence for a
the meaning of
the significant scientific agreement (SSA)
scientific evidence to support a qualified
Soon after this latest guidance was issued, FDA
was criticized for allowing Qualified Health
Claims in a Center for Science in the Public
Interest (CSPI) press release. Food Label
News has reported extensively on pressures
to eliminate this type of claim. FDA continues
to allow the claims in response to legal
challenge that called use of such claims a right
under the U.S. Constitution First Amendment
right to free speech. See earlier Food Label
FDA Issues Food Labels Guidance - Seafood List
In January 2009,
FDA issued "Guidance for Industry - The Seafood
List - FDA's Guide to Acceptable Market Names
for Seafood Sold in Interstate Commerce." The
FDA considers to be acceptable market names
for seafood sold in interstate commerce
different categories of names found in "The
principles that can be used to label seafood
species sold in the United States with an
appropriate, non-misleading statement of
Food Consulting Company can help with product
naming for seafood and all FDA-regulated foods
when you order
Full Label Compliance
Label Compliance Review.
At Your Service: Labeling products
with consumer appealing statements of
fact and FDA compliant label claims can help
products sell. For help,
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