8, Number 9 - September 2007
IN THIS ISSUE:
About Food Consulting Company
"Thank you for the outstanding job.
Your professionalism is impressive.
We're a big company and I'll be contacting
you for new products."
Greetings! If getting your new or newly
formulated products labeled for compliance with
FDA regulations means that you must spend hours
reading FDA regulations, consider that Food
Consulting Company can expertly handle the label
work for you. Choose
Full Label Compliance.
Q. What is
the legal definition for "trans fat free?" Can a
restaurant or product make this claim?
J.P., Consultant, Massachusetts
date, FDA has not established a definition for
"trans fat free." Therefore this
claim cannot be made
on food labels or on menus and menu boards, or
in food marketing. Read more:
Reader Q&A page.
Submit a question
for Reader Q&A (no charge).
FDA Begins Public Look at Food Labels Symbols
On September 10 and 11, 2007, FDA is conducting
a public hearing to gather information regarding
the use of symbols on food labels. FDA is referring to the
symbol programs that have been instituted by
organizations such as health advocacy, food
manufacturers, grocery stores, and trade groups to communicate
nutrition information to consumers.
A July 20, 2007,
Federal Register notice
describes the scope of the hearing. In part
FDA's questions are:
What are consumers' attitudes toward
Do nutrition symbols direct
consumers toward purchase of foods that bear
How do consumers interpret food label
symbols in relation to the Nutrition
Do symbols on food labels affect the nutritional quality of
a consumer's diet?
To what extent have products been developed/reformulated to qualify for a
Food Label News, November
2006, reported on symbol programs
offered by organizations to convey information
about whole grain content to consumers. Under
current regulations, labels can contain
voluntary symbol information as long as the
message is truthful and not misleading.
Food Labels Health Claims Get Attention
On July 9, 2007, FDA released "Guidance for
Industry, Evidence-Based Review System for the
Scientific Evaluation of Health Claims -
The draft explains the evidence-based review
system FDA intends to follow when evaluating the
scientific evidence in petitions that are
submitted for significant scientific agreement (SSA)
health claims or qualified health claims. Health
claims that meet the SSA standard are authorized
by publication of a final rule or an interim
final rule in the Federal Register. For health
claims not meeting SSA criteria but supported by
credible evidence (i.e., qualified health
claims), FDA issues a letter regarding
its intent to consider enforcement discretion.
Meanwhile, on August 2, 2007, the United States
House of Representatives (House) passed the
Agriculture, Rural Development, Food and Drug
Administration, and Related Agencies
Appropriations Act, 2008 (H.R.3161). Included in
this Act is the statement, "No funds in this Act
may be used to authorize qualified health claims
for conventional foods." The Center for Science
in the Public Interest praised this action in an
August 7, 2007,
Food Label News queried an FDA spokesperson
about how FDA would act regarding
qualified health claims if the House measure
becomes law; the spokesperson responded, "As
a matter of policy FDA generally does not
comment on proposed legislation."
FDA Guidance - Helpful for Food Labels Work
Food labelers can benefit by periodically
reviewing FDA's list of guidance documents.
Guidance documents describe the Agency's current
thinking on a policy or regulatory issue; they
are intended to establish common understanding
between and among stakeholders. FDA is required
to issue guidance documents whenever regulatory
expectations are not readily apparent in
published regulations. Members of the
public can suggest that FDA draft a new guidance
document or revise or withdraw an existing
list of guidance documents.
Commentary: Food Consulting Company routinely
cross references information from FDA guidance
documents with other sources of regulatory
information such as the Code of Federal
Regulations, Federal Register notices of final
rules and various FDA web pages.
Label Compliance Review is the service to choose to confirm that
the labels you develop in-house are 100% FDA
Full Label Compliance
to have Food Consulting Company prepare labels
that are 100% compliant for your products.
At Your Service: Calories on Menus/Menu
It is likely that sooner or later, by law or
public pressure, fast food and other chain
restaurants will be forced to provide calorie
information at point of purchase.
Consulting Company can help get the job done.
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