Volume 11, Number 3 - March
Hello from Food
As your virtual food labeling department, we understand your
challenges and concerns and we're delighted to keep you
current and in the know. In this issue we spotlight the
ongoing negotiation with marketing. We hope you find the
insights useful. Please do let us know!
Say "YES" to Marketing
What do you do when your
marketing department wants to get creative with the package
copy and they're on the brink of regulatory blunder? How do
you position your products in the best light while ensuring
It is possible to both ensure
your labels are 100% compliant and give marketing the
saleable claims they need. We suggest taking these three
guidelines into account:
"negotiation" with a can-do attitude – Consider what
would be allowed instead of focusing on what is not
allowed. You may be surprised how your cooperative
approach can set the tone for effective problem solving.
There's more than one way to say what you mean –
If the objective is to communicate a benefit to
consumers, consider a statement of fact in a starburst
rather than a defined nutrient content claim.
Know your facts – If you have a clear
understanding of nutrient content claims, health claims,
structure/function claims, dietary guidance statements
and statements of fact, you will be more confident in
suggesting alternatives that achieve both regulatory and
With these guidelines in mind,
it's reasonable to believe that we can balance a powerful
message to consumers while ensuring 100% regulatory
Instructional Series (see below) provides guidance so that
you can say "YES" to marketing.
Keeping You Current
Institute of Medicine's Study Staff for Front-of-Pack
labeling posts FDA presentations from
first meeting [1,
to 16 companies for false and
misleading food label claims
in February 2010
FSIS extends comment period for nutrition labeling of
single-ingredient meat and poultry
FDA issued a
proposed rule requiring
research sponsors to report information regarding falsification of data
for label claims
New York Times reports that FDA is actively re-evaluating
serving sizes used in
White House establishes a
task force on
Health Canada proposes stricter
ingredient labeling for added colors
Often it's tricky
to navigate the nuances of FDA food regulations.
Food Consulting Company offers a clear understanding of
nutrient content claims, health claims, structure/function
claims, dietary guidance statements, and statements of fact.
As a result, we're able to help our clients craft label
statements that satisfy the needs of both marketers and the
Statements of Fact on Food Labels:
Instructional Series Part 7 of 10
installment in our ten-part series describes the use
of statements of fact on food labels.
This 10-part instructional series is based on a 2009
publication titled "Silliker Nutrient and Health
Claims U.S. Regulatory Guide" that was cooperatively
developed by Food Consulting Company and Silliker,
Inc., a leading provider of laboratory nutrition
Part 7 of the
As we pointed out in
last month's series, the words "only 3g carb per serving"
constitute a disallowed implied nutrient content claim. If
you drop the word "only" and simply state "3g carb per
serving" you are making a statement of fact which is
allowed. You will see several other useful examples in the
Guide. Also, view a previous
Reader Q&A about 0g trans
fat on food labels.
If you missed
earlier parts of the series you can view and download them
Part 6.) The pages from all parts
will add up to the complete booklet.
What does FDA require regarding redemption value
labeling for beverage containers?
− A.S., Beverage Marketer, Florida
FDA does not regulate this
aspect of beverage labeling. Rather, it is regulated by
the individual states. The requirements vary depending
on type of container (plastic, glass, aluminum, etc.),
contents of the container (carbonated, non-carbonated,
juice, etc.) and if the container is marketed as single
or multi-serving. The Container Recycling
Institute maintains a website at
outlines the various requirements for U.S., Canada
More reader questions
At Your Service
founded in 1993, provides nutrition analysis, food labeling
and regulatory support to ensure 100% compliance with FDA
regulations. With over 1,000 clients worldwide, Food
Consulting Company's services are ideal for start-up and
established food manufacturers, distributors, food
importers, brokers, and restaurateurs.
Contact Us for more
information about your food labeling needs.
You may reprint all or part of this newsletter,
provided you attribute it to Food Label News
and include a link to
2010. Food Consulting Company, Del Mar, CA. All rights reserved.