6, Number 9 - September 2005
IN THIS ISSUE:
About Food Consulting Company
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– Diana Michiulis,
Sr. Scientist Regulatory Affairs
Kraft Foods R&D Munich, Inc.
Dear Readers, This
month Food Label News reports the answers
obtained from an FDA spokesperson to recent
reader questions that pertain to January 1,
2006, requirements for trans fat and food
allergen labeling. Food Consulting Company can
help you tackle all stages of your food labeling
projects, and we can answer the tough questions
that hold you from completing your projects.
for the help you need.
January 1, 2006 Compliance Date
In February 2005, Food Label News reported on a
letter from food industry members requesting
that FDA harmonize the triggers for January 1,
2006, food label requirements. An FDA
spokesperson has confirmed that FDA declined the
request. The triggers for January 1, 2006,
Per the spokesperson, the "labeling of products"
trigger means that food products that are
produced and labeled prior to January 1, 2006,
which are part of a firm's inventory, may be
distributed in interstate commerce after January
1, 2006, until the product inventory is
exhausted. However, the "entry into interstate
commerce" trigger requires a trans fat listing
in the Nutrition Facts for foods that enter
interstate commerce on or after January 1, 2006;
foods that enter interstate commerce prior to
January 1, 2006, are not affected.
Access FDA links for trans fat and allergen
See Food Label News report on the harmonization
Commentary: Due to FDA's decline to
harmonize triggers, manufacturers need to plan
to have products with "old" labels in interstate
commerce no later than December 31, 2005. It is
worthy to note that products without trans fat
and allergen labeling can legally be on store
shelves after January 1, 2006; this will be the
case if the products entered into interstate
commerce on December 31, 2005 or earlier.
Clams/Oysters -- Not Required Allergens on Food
The Food Allergen Labeling and Consumer
Protection Act of 2004 (FALCPA), requires only
that the presence of crustacean shellfish
(shrimp, lobster, crab, crayfish, prawns) in a
food, and not the presence of mollusk shellfish
(oysters, clams, snails, mussels, scallops),
must be indicated in the food label allergen
statement. A spokesperson for FDA's Center for
Food Safety and Applied Nutrition confirmed that
food labels would be in compliance with FALCPA
when only crustacean shellfish are identified.
Commentary: Food Consulting Company
sought FDA comment on the wording of FALCPA,
which specifically states "crustacean shellfish"
since many food allergen lists identify
"shellfish" as one of the eight most common
allergens, without distinguishing between
crustacean and mollusk.
Nutrition Labels for
Children -- No Trans Fat Exemption
A spokesperson from FDA's Center For Food Safety
and Applied Nutrition confirmed with Food
Consulting Company that foods labeled for
children less than two-years of age are required
by the trans fat final rule to declare trans
fatty acids within the nutrition facts label of
products that enter into interstate commerce on
or after January 1, 2006.
Read trans fat final rule:
Commentary: Food Consulting Company
sought FDA comment on the trans fat requirement
because the Nutrition Labeling and Education Act
restricts foods intended for children less than
two-years of age from listing calories from fat,
saturated fat, polyunsaturated fat,
monounsaturated fat, and cholesterol in the
nutrition facts label. However, the trans fat
final rule does not exempt foods for children
less than two-years of age from the trans fat
Consulting Company can answer or get answers to
your tough food labeling questions. Submit your
the option for Regulatory Research. Your
question will be answered within 10 business
days when you choose standard service; rush
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