Does your food packaging meet the six big requirements outlined in the Federal Food, Drug and Cosmetics Act, the Fair Packaging and Labeling Act and the Food Allergen Labeling and Consumer Protection Act? Let’s get up to speed on the requirements:
1. Statement of Identity
2. Net Quantity of Contents
3. Nutrition Labeling
4. Ingredient Statement
5. Allergen Declaration
6. Name and Place of Business of Manufacturer, Packer or Distributor
The statement of identity is the common or usual name for your food product as defined by law or regulation. You can determine your proper statement of identity for your product in the Code of Federal Regulations, Title 21, parts 102 and 130-169. If your food is unique and has not been identified, you can give it a name that accurately and appropriately describes it.
The net quantity of contents is the weight or fluid measurement of food as it’s sold in its retail package. The net quantity must be shown both in U.S. customary system (pounds, ounces, fluid ounces) and metric terms (grams, kilograms, milliliters, liters). If your product exceeds one pound, you must state the weight in both pounds and ounces. For example, if your product weighs 20 ounces, you must state it as 1 lb 4 oz. The metric term is placed in parentheses following the U.S. customary term. In addition, you must say “net wt” or “net” (for fluid measurements) prior to the measurement. Here are some examples:
- Net Wt 1 lb 4 oz (567g)
- Net 8 fl oz (237 mL)
Nutrition labeling is displayed in a Nutrition Facts panel. A Nutrition Facts panel has three components: serving size, nutrient values and a footnote. Depending on the nutritional makeup of your food and its packaging, there are several options available. The most common FDA approved label is a standard Nutrition Facts panel, which is a vertical panel containing all three components. Other formats include tabular, linear, dual declaration, aggregate, simplified and shortened. Some food manufacturers are exempt from nutrition labeling under the small business exemption amendment.
An ingredient statement is a listing of all ingredients used to fabricate a food. The ingredient must be listed as a common or usual name. Ingredients are required to be listed in descending order of predominance by weight (from greatest to smallest). Multi-component ingredients must list sub-ingredients in parenthesis. For example the ingredient flour may be listed in the ingredient statement as “Enriched Flour (Wheat Flour, Malted Barley Flour, Niacin, Reduced Iron, Thiamine Mononitrate, Riboflavin, Folic Acid).” Special rules apply to spices, flavorings and colorings.
An allergen declaration came into effect in January 2006. It requires food manufacturers to declare if their product contains one of the eight major allergens. The eight major food allergens include:
- Tree nuts
- Crustacean fish
Allergens can be listed in the ingredient statement or in a separate declaration statement. Tree nuts, fish and Crustacean fish must be listed by type. For example, you should list allergen as containing “pecans,” “tuna,” “shrimp,” not “tree nuts,” “fish,” or “Crustacean fish.”
And finally, the last of the big requirements is the name and place of business of manufacturer, packer or distributor. You must include:
- Name of manufacturer, packer or distributor
- Street address (if not listed in current phone directory)*
- Zip Code
*A post office box cannot be used. The addition of a phone number or website address is optional.
For more information or assistance with your food labels, please call the experts at On The Menu, LLC.