Volume 17, Number
4 -
April 2017
Greetings from Food Label News!
This month we explore one of the most talked-about
topics: when it's acceptable to group ingredients within
the Ingredient Statement. Read on to learn the specifics
for this widely enforced FDA regulation. You'll also
read about the appropriate use and implications of using
hangtags, a response to a reader's question. Please send
us your questions and we'll be sure to provide answers
either in the
Food Label Community or future issues of Food
Label News.
In this issue you'll find:
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"Your
input was insightful, realistic
and incredibly valuable. Thank
you!"
–
Amanda Berhaupt-Glickstein, MS,
RD
Rutgers University
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Karen C. Duester, President
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More About Ingredient Labeling:
When to
Use Collective Names
A common question to both Food Label News
and the Food Label Community is when it's
allowable to combine ingredients in the
Ingredient Statement. It's a marketer's goal
to list favorable ingredients as close to
the top as possible. In some cases this is
feasible, however it is more of an exception
than the norm.
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FDA regulations require food labelers to
list ingredients in descending order of
predominance by weight in packaged foods.
The name of an ingredient used in the
Ingredient Statement must generally be a
specific name and not a collective name.
There are, however, several specific
situations where collective naming is
allowed. These include: |
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Ingredients with established common or usual
names Worchestershire sauce, mustard and
tomato sauce are widely established products
and therefore the common name may be used
for the combined ingredients followed by
individual ingredients in parentheses.
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Ingredients with standards of identity
Bread, ice cream and French dressing all
have standards of identity so listing
individual ingredients in parentheses after
the standard name is allowed.
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Milk products Different forms of milk such
as concentrated milk, reconstituted milk and
dry whole milk can be combined and listed
with the shortened name "milk" without any
parenthetical ingredients. The same concept
applies to different forms of skim milk,
cream, whey and buttermilk.
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Egg products Different forms of eggs such
as dried whole eggs, frozen whole eggs and
liquid whole eggs can be combined and listed
with the shortened name "eggs" without any
parenthetical ingredients. The same concept
applies to egg whites and egg yolks.
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Fat and oils These can be listed collectively when they
are part of a blend, for example, vegetable
oil (corn, canola and soybean oil).
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Fish protein ingredients in processed
seafood products This exception applies
only when the manufacturer is unable to
adhere to a constant pattern of fish species
because of seasonal or other limitations of
availability. For example, fish proteins (pollock,
cod and/or pacific whiting).
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Wax and resin on fresh produce These
coating ingredients require specific wording
to accompany the collective name, for
example, coated with beeswax and/or lacresin.
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Specific functional classes of ingredients
can list the collective name in the
Ingredient Statement followed by the
individual types in parentheses. Examples
include:
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Leavening agents Leavening (baking
soda, monocalcium phosphate, calcium
carbonate) |
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Yeast
nutrients Yeast nutrients (calcium
sulfate and/or ammonium phosphate) |
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Dough
conditioners Dough conditioners
(L-cysteine, ammonium sulfate) |
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Firming agents Firming agents
(calcium carbonate and/or calcium
sulfate) |
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Flavors, Spices & Colors Many of these can
be listed by a collective name, however
there are important exceptions and caveats.
Stay tuned to Food Label News for more on
labeling these important and often tricky
categories. |
Food labelers wishing to use collective
naming should consult all applicable sections
of the Code of Federal Regulations, starting
with
21CFR101.4 and
21CFR101.22.
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We often get specific questions
about how to list combinations of nuts,
fruits, grains and juices in the Ingredient
Statement. The regulations do not allow
collective ingredient labeling for
ingredients like these, therefore, examples
like the following are NOT allowed:
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Nuts
(almonds, peanuts, walnuts) |
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Dried
fruits (cherries, blueberries,
raisins) |
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Grain
mix (oats, brown rice, quinoa) |
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Fruit juice concentrates (apple,
grape, cherry) |
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FDA watches collective naming
carefully. We only need to recall the FDA
warning letter to KIND, LLC in 2015 citing
that listing the collective terms "mixed
nuts," "dried fruits" and "vitamins" as
multicomponent foods and declaring the
specific nuts, fruits and vitamins as
sub-ingredients is not allowed.
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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.
Q.
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Can I attach a tag to a jar of
fruit spread since I do not have
room for a conforming Nutrition
Facts label?
− K.S., New York, Food
Manufacturer
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A.
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Yes, this is possible. If a
manufacturer chooses to add
label space for any purpose with
a hangtag then this additional
space is included in the total
available space for labeling.
This combined space determines
the minimum type size
requirements for all label
components including the
specific Nutrition Facts format
to be used. In addition, the tag
must adhere to the package
throughout storage and shelf
life conditions.
Read more.
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What Matters in Food Labeling
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