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Volume 6, Number 6 - June 2005


About Food Consulting Company

"As a new product development firm, we rely heavily on the prompt service and expertise that Food Consulting Company provides. This allows us to focus on our own tasks and provides peace of mind knowing the regulatory items are covered."

– Jeff Liebrecht
Innovative Food Solutions, LLC

Greetings! By now food labelers have one of two feelings about the upcoming January 1, 2006, compliance date for allergen and trans fat labeling -- confidence or anxiety. If you are feeling anxious about the upcoming date, Food Consulting Company can help you get labels ready. Request help:

FDA & FSIS Modernize Standards of Identity for Food Labels

FDA and USDA's Food Safety and Inspection Service (FSIS) have initiated steps to modernize Standards Of Identity (SOI's). The agencies have established a set of general principles, published as a proposed rule on May 20, 2005, for evaluating whether to revise, eliminate, or create new SOI's for food. Interested parties may submit comments to either agency (FDA or FSIS) at until August 18, 2005.

Read press release:

Read proposed rule:

Commentary: This rule relates to how some products must be named on the food label. Not all products have SOI's, but other naming rules apply. Food Consulting Company answers more regulatory questions on product names than any of the other four FDA-regulated food label components. If you have a question about a product name, submit a Regulatory Question at

CSPI Litigates Deceptive Food Labels

In a May 3, 2005, press release, Center for Science in the Public Interest (CSPI) announced that the organization is increasing legal action against deceptive food labeling, fraudulent advertising, and the use of dangerous food additives; an attorney has been hired to direct the litigation efforts. CSPI says the steps are necessary since FDA and the Federal Trade Commission (FTC) have done a poor job enforcing the law in these areas.

Read CSPI press release:

Commentary: If you are seeking assurance about the accuracy of your food labels, request a Label Compliance Review at Food Consulting Company will examine your food labels to assure that they are in full compliance with FDA and FTC regulations. You will receive a report with instructions for any necessary changes.

Food Labels Allergen Information Collection Described

FDA has published a proposed collection of information that seeks to gauge the impact of "allergenic ingredient" information on food labels. FDA also wants to determine how consumers with food allergies or their caretakers prefer to have information about the risk of cross-contamination (shared equipment) be communicated on food labels. The information is being collected to fulfill requirements of the Food Allergen Labeling and Consumer Protection Act of 2004. FDA requests comments on the design of the proposed collection by June 9, 2005.

Read Federal Register notice:

Commentary: This study or its outcomes will not in any way affect the January 1, 2006, requirements for allergen labeling. See Q&A on January 1, 2006, requirements at

FYI:  On May 7, 2005, Health Canada published amendments to Canadian Food and Drug Regulations pertaining to nutrition labeling, nutrient content claims, and health claims. The original regulations were published on December 12, 2002; most food companies must comply by December 12, 2005.

Access Canada's Nutrition Labeling website:

Read new amendments:

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