Labeling spices in ingredient statements can be confusing. It’s common practice for manufacturers to label spices in ingredient statements as “spice” or collectively, “spices.” This allows two things, a more concise ingredient statement and the ability to “hide” a proprietary formula.  However, it’s important to follow FDA regulations when using the term “spice” in an ingredient statement.

Definition of Spice

The FDA’s criteria for something to be considered a “spice” include:

Any aromatic vegetable substance in the whole, broken or ground form.

The significant function in food is seasoning rather than nutritional.

Material is true to its name and no portion of any volatile oil or other flavoring principle has been removed.

Exceptions

Exceptions to this rule include, salt and any ingredients traditionally thought of as food. Things like garlic, onion, celery or anything derived from a fruit, vegetable, meat, fish or poultry that are commonly understood to be food rather than flavor must be declared by their common name regardless of the form, or processing, i.e. dried, powdered, granulated etc.

Also, extracts are not considered “spices,” but rather, are “flavors” and may be labeled using their common names or as “natural flavor.”

Additionally, some “spices” may play roles other than seasoning and must be labeled accordingly. For example, paprika, turmeric, saffron and other spices which may be added for color as well as flavor, must be listed as “spice and coloring” or by their common name. If the sole purpose of that ingredient is coloring, then it must be labeled indicating the purpose, i.e. turmeric (coloring) or coloring (turmeric).

Using blended spices can be tricky too.  Most blended spices contain both “spice” and “non-spice” components like salt, garlic powder, etc. The non-spice components must be identified but the spice portion of the blend may be labeled as “spice.”

FDA List of Spices

For a complete list of spices go to this link http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm and search “182.10” in the Title21 Part.Section field. Ingredients not on this list must be called by their common name.

For Further Help

If you have questions about labeling spices in ingredient statements, On The Menu can help answer your questions and provide clarity to the rules. We make sure our clients’ ingredient statements are FDA compliant. Contact us for assistance.