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Volume 11, Number 11 - November 2010

Hello from Food Label News. From shiny ovens and work tables to recycled beverage cans, we celebrate our 10th anniversary of publishing Food Label News glittering with pride. In this issue we take a look back to see how far we and the industry have come.


As we mark the 10th year of bringing you this e-newsletter, we invite you to join the Food Label Community and expand your network further. Thank you to those who have already connected with us on LinkedIn.


We look ahead to the next 10 years as we broaden our circle and yours!

In this issue you'll find:

Karen C. Duester, President


"I think a lot of  Food Label News. My boss was RAVING about it as well. You cover items and issues that are overlooked in the trade magazines."

– Steve Wilk
Costco Wholesale



A Decade in Review

A decade ago began our new millennium. We witnessed the biggest merger in the country's history as America Online bought Time Warner, Oprah Winfrey launched O Magazine, and the U.S. dominated the Summer Olympics in Sydney with 40 medals.

The food industry also has had its share of developments and milestones. The "low carb" fad has come and gone but "healthy" is here to stay. We've seen the impact on our food labels including new regulations for trans fat and allergen declarations, the growth of natural and organic foods, as well as the demand for lower sodium alternatives. New regulations for Front-of-Pack and restaurant menu labeling continue the momentum toward helping consumers make smart food choices.

Throughout this decade, Food Label News has kept you current. We take this opportunity to reprise the hottest topics of the last 10 years, based on feedback from you, now 6,000 readers strong. It's more than nostalgia – these topics are as relevant today as they were when they were first reported.

  • Trans fat and allergen labeling – January 1, 2006, marked the first time FDA required food labelers to include trans fat within the Nutrition Facts Panel. At the same time, Congress required that the "Big 8" allergens be identified in plain common English in the ingredient statement or in a separate "Contains" statement. See Food Label News 2006 web page.

  • Front-of-Pack labeling – Over the past several years a plethora of nutrition symbols and systems appeared on the front of packages which confused consumers and food labelers alike. Food Label News reported on the December 2008 FDA roundtable and provided access to the FDA slides to our  readers.

  • Regulatory Guide for Label Claims – We collaborated with Silliker to develop a regulatory guide that summarizes nutrition claims on food labels. Food Label News featured the guide as a 10-part series. View Silliker Nutrient and Health Claims U.S. Regulatory Guide.

Keeping You Current

Phase I report on Front-of-Pack labeling from IOM

GMA-FMI Front-of-Pack Nutrition Labeling Initiative recently announced

Nutrition Facts Education Campaign: a new collaboration between Health Canada & Food and Consumer Products of Canada

Food Additive Petition Expedited Review guidance revision from FDA

Lawsuit over "misleading multivitamin claims" settled by State of California & Bayer

From the Archive

Q&A's about allergen labeling:

Advisory allergen labeling

"Contains" allergen statement

Release agents as ingredients

Lecithin as an allergen

Nut and soybean oils

MSG ingredient listing


In the next 10 years we predict changes in food labeling regulations that will have widespread impact on the industry. For example, changes to the Nutrition Facts Panel are likely to include: serving sizes more aligned with consumer behavior, formatting that makes calories more prominent, modifications to mandatory and voluntary nutrients, and changes to daily values consistent with IOM reports. We look forward to keeping you current on these and other issues important for food labelers.

5 Must-Haves for FDA Food Labels:
Instructional Series Part 4 of 5

In the last three months, we have profiled the five required components for every FDA regulated food label. In addition to Product Identity, Net Contents Statement, and Nutrition Facts, the fourth required component is the Ingredient Statement.

Ingredient Statement

All ingredients contained in the formula must be listed on the food label in descending order of predominance by weight. That is, the ingredient that weighs the most is listed first and the ingredient that weighs the least is listed last. Other regulations regarding the ingredient statement include:

  • Ingredient names - Specific common or usual names of the ingredient must be used. For example, "sugar" is used instead of "sucrose". An exception is that non-certified colors, flavors, and spices may be listed collectively provided they are not derived from known allergens (see further explanation in the bull's eye section below).

  • Placement - The ingredient list is placed on the same label panel as the name and address of the manufacturer, packer or distributor. This may be either the information panel (IP) or the principal display panel (PDP).

  • Type size - Use a type size that is at least 1/16 inch in height (based on the lower case "o" unless all upper case letters are used) and that is prominent, conspicuous, and easy to read.

Consult the FDA Food Labeling Guide for more information about the ingredient list on food labels.

Major food allergens (the "Big 8") must be declared on all food labels in the U.S., as required by the Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA), Title II of Public Law 108-282. Major food allergens are: crustacean shellfish, egg, fish, milk, peanut, soybeans, tree nuts and wheat. These major food allergens account for 90% of all food allergies. Allergens other than these "Big 8" are not subject to FALCPA labeling requirements. For more information about listing allergens, the "Contains" statement and advisory labeling about cross-contamination, consult From the Archive in this issue (above right).

Reader Q&A

Find answers to our readers' questions or send us your question for an upcoming issue.


Can my product (an aseptically shelf stable ready-to-eat pudding) that is made in the U.S. and labeled for sale in Canada state "2% or 1% or less" in the ingredient statement?
A.H., Established Food Company, Pennsylvania


Canadian regulations make no mention of an "X% or less" clause for ingredient statements. In the U.S., the clause "2% or less of the following" (or 1.5%, 1%, or 0.5%, as appropriate) can be used at the end of the ingredient statement to list minor ingredients in any order. Canadian regulations specify that ONLY specific classes of ingredients can be shown at the end of the ingredient statement in any order. For these specific classes of ingredients in Canada, the "X% or less of the following" clause could be used, but it is not common practice because it significantly lengthens the ingredient statement given the English-French bilingual labeling requirement. Read more.

At Your Service

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With well over 1,000 clients worldwide, we’re pleased to provide information to address your food labeling needs.

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