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Volume 9, Number 7 - July 2008


About Food Consulting Company

"Thank you for helping us understand what our group has struggled with for so long. You made it seem so simple."


~ Becky Kingery
Endangered Species Chocolate

Dear Readers,  Thank you to all who submitted responses to the recent Food Label News survey regarding what factor is most likely to slow progress on label development projects. From the survey results "incomplete data from ingredient suppliers" is the factor that most frequently slows label work. This issue of Food Label News offers tips to overcome this factor.

Q.  I frequently get incomplete nutrition information from ingredient suppliers and my nutrient analysis program only helps part of the time. How can I get complete information?          S.J., Cookie Company, Illinois


A.  When complete and accurate nutrition information is not provided by ingredient suppliers or readily available from a particular database, accurate values must be obtained through a process of due diligence. Read more.

Submit a question for Reader Q&A (no charge).

Survey Results - Top Delays in Food Labels Work

In March and April 2008, Food Label News asked readers to report back to the newsletter indicating what factor is most likely to slow label development projects. Readers were to consider four factors or to identify a factor not listed. The factors and percents (rounded) chosen by readers were:

  • formula stability and shelf life issues - 0%

  • product positioning and front-of-pack label development - 0%

  • Nutrition Facts and ingredient/allergen labeling - 30%

  • nuances of understanding FDA food label regulations - 30%

  • other (please specify) - 40%

Of the 40% choosing "other", all indicated that compiling accurate, detailed nutrient data for ingredients was the factor most likely to slow food label work.

Karen Duester, president of Food Consulting Company, explained to Food Label News that the company's service providers are also frequently faced with incomplete data from suppliers. Despite lack of data, Duester said labelers are obligated to report accurate nutrient values in Nutrition Facts. Labelers must utilize a combination of deep food composition knowledge and professional wisdom to find or reasonably deduce values when complete nutrient data are not readily available.

See Reader Q&A above and corresponding due diligence article for an explanation of the process used by Food Consulting Company to report accurate Nutrition Facts values.

Commentary:  A research quality database that contains complete USDA Data is indispensable for producing Nutrition Facts. Food Consulting Company uses Genesis R&D SQL by ESHA Research. Karen Duester, company president, has been a trainer for ESHA software for ten years.

Update on Sodium and Food Labeling

A June 11, 2008, Federal Register Notice, announced that FDA reopened the comment period regarding whether FDA should change salt's regulatory status from GRAS (generally recognized as safe) to food additive and require limits on salt in processed foods. Comments can be submitted until August 11, 2008.

The comment period is subsequent to FDAs public meeting on the regulatory status of salt that occurred on November 29, 2007. The meeting transcript is posted on as Docket Number 2007-0545.

The notice to reopen the comment period is posted on as Docket Number 2005-p-0196.

Commentary:  See earlier Food Label News reports on the regulatory status of salt: November 2007 and January 2008.

FDA Warns Companies to Stop Using Certain Claims

In a June 17, 2008, press release, FDA announced that warning letters were sent to 23 U.S. companies and two foreign individuals who fraudulently claimed on websites that certain products could prevent and/or cure cancer. Companies that fail to properly resolve the cited violations are subject to enforcement action up to and including seizure of illegal products, injunction, and possible criminal prosecution.

The warning letters are part of FDA's ongoing efforts, in collaboration with the Federal Trade Commission (FTC) and Canadian government agencies, to prevent deceptive products from reaching consumers.

See FDA press release.

In a November 1, 2001, letter, FDA states its position regarding product claims posted on websites. The letter is a response to a petitioner who asked FDA to exempt Internet information of food companies from labeling requirements. In the letter, FDA refuses to exempt Internet information and explains the basis for enforcement action. Read Food Label News report (January 2002) and access the FDA letter.

Commentary:  Food Consulting Company can help assure your Internet promotion of products is compliant with FDA and FTC regulations. Order Regulatory Support.

At Your Service:  Food Consulting Company expertly completes the due diligence for hundreds of food labelers each year. Order Full Label Compliance or Nutrition Facts Panels for accurate nutrition analysis.

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