Food Label News, Government Actions for Food Labels, FDA Regulations, Food Labels, Nutrition Labels
Food Label News ArchiveFood Label News SubscriptionsNutritional Analysis Food Labels - Food Nutrition Facts LabelsFood Consulting Company: Nutrition-Labeling-Regulatory

Volume 6, Number 4 - April 2005


About Food Consulting Company

"You came through with flying colors delivering my work a few days earlier than was expected!  I am very pleased and look forward to launching new products in the very near future. Thank you!"

– Jeffray Gardner, President & CEO
Marsatta Fancy Chocolates

Spring greetings to everyone. If you haven't yet updated your labels to meet the January 1, 2006, requirements for trans fat and allergen labeling, now is a good time.

Food Consulting Company is receiving calls daily regarding the requirements. Some of the most frequently asked questions are addressed in this issue of Food Label News.

Expert help to get your labels ready is available from Food Consulting Company. Go to

January 1, 2006-Compliant Food Labels - Good Until 2008

Since 1996, FDA has announced Uniform Compliance Dates for final rules that require food label changes. The Uniform Compliance Dates mean that food companies do not have to respond separately to each regulatory change.

FDA set January 1, 2006, as the Uniform Compliance Date for food labeling regulations that were issued between January 1, 2003, and December 31, 2004. Nearly all labels require revision to include trans fat and specific food allergen information by this upcoming compliance date.

Once food labels meet the January 1, 2006, requirements, labels will be in compliance until at least January 1, 2008. A March 14, 2005, Federal Register notice announces January 1, 2008, as the Uniform Compliance Date for labeling regulations that are issued between March 14, 2005, and December 31, 2006.

Read Federal Register notice:

Commentary: All changes required on food labels by January 1, 2006, were announced in the Federal Register and reported by INTOUCH/Food Label News prior to December 31, 2004. This means labelers have twelve months to get labels ready. Many clients have expressed concerns that labels will require changes right after they are updated for January 1, 2006, compliance. Labelers can put these concerns to rest. Required label changes that are due January 1, 2008, will be announced well in advance and labelers will have at least a full year to prepare labels with required changes.

Trans Fat Needed on Nutrition Labels - Even if 0 Grams

By January 1, 2006, nearly all FDA-regulated foods labeled for sale in the United States must comply with FDA requirements for trans fat labeling. The amount of trans fat, even if the amount is 0, must be declared on the Nutrition Facts panel.

Products that qualify to bear a "simplified Nutrition Facts" and that have a 0 value for total fat are not required to report trans fat. If a product is exempt from nutritional labeling, reporting trans fat is not required. However, products falling into these categories may still require label revision to comply with the new allergen labeling law.

See Q&A on January 1, 2006, requirements:

Access FDA documents on trans fat labeling:

Order help with trans fat labeling:

Commentary: Food Consulting Company clients can be assured that the Nutrition Facts panels prepared for them comply with regulations based on the product type, package size, and ingredients. Others who are unsure of the requirements for their label type can order a Label Compliance Review of their current labels. Order this service:

Food Labels Allergen Law - Voluntary Labeling May Differ

Allergen labeling requirements, as established by Public Law in November 2003, are mandatory on nearly all food labels beginning January 1, 2006. Many food labels included voluntary allergen information prior to establishment of the law, however the information may not satisfy the new requirements.

The new law identifies food allergens as milk, eggs, wheat, soybeans, peanuts, tree nuts, fish, and shellfish. If a food or an ingredient in a food contains or has been in contact with any of these allergens, the product label must indicate this in plain or common language. This information can be declared in the Ingredient Statement or in a separate Allergen Statement.

See Q&A on January 1, 2006, requirements:

Access FDA website for Public Law:

Order allergen testing and label help:

Commentary: Food Consulting Company clients can be assured that all ingredient lists and allergen statements that have been prepared for them since establishment of the allergen law are in full compliance with the January 1, 2006, requirements. Other labelers who have concerns about allergen reporting on their labels can request a Label Compliance Review. Order this service:

FYI:  While food labels are being updated to comply with January 1, 2006, requirements, labelers will want to review Serving Sizes on the Nutrition Facts panel, since FDA has pledged to make accurate serving size declarations a priority. For earlier report, see April 2004 INTOUCH:
Get more from Food Label News: Send comments.

Please share this newsletter in its entirety, including subscription and copyright information.

© Food Consulting Company, 2005
13724 Recuerdo Drive, Del Mar, CA 92014 USA
tel 800-793-2844 or 858-793-4658
fax 800-522-3545 or 858-712-3323