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Volume 11, Number 12 - December 2010

Hello from Food Label News. With the season of gingerbread and spiced cider upon us, its a great time of year to reach out and connect with your colleagues in the Food Label Community.

We hope you can take a break from the business of food labeling this holiday season and enjoy happy times with family and friends.

Happy Holidays from your friends at Food Consulting Company.

In this issue you'll find:

Karen C. Duester, President


"As a new entrepreneur in the world of food marketing, I can't thank you enough for your professionalism, insightful knowledge, and friendly manner in helping me to understand compliance issues and for getting my label ready for market. You made everything seem so easy, and your turn-around time was incredibly swift! You are a pleasure to work with and always supportive. I look forward to working with you on my next two mustards."

Vivian Poutakoglou
Vivi's Original Sauce, LLC

Front-of-Pack Food Labels:
Where Will the Dust Settle?

As marketers seek to persuade consumers to try their products, the front-of-pack (FOP) has become a billboard to communicate benefits. Over the past several years a plethora of nutrition symbols and systems have appeared on the front of packages which confuse consumers and challenge food labelers. Sorting through what is acceptable and what is not is the next regulatory hurdle.

Here's what we know:

IOM Report - In October, the Institute of Medicine (IOM) released a Phase 1 report of their in-depth evaluation of current FOP systems. They segmented 20 representative systems into three categories:

  1. Nutrient-Specific Systems: e.g., UK Traffic Light, General Mills Nutrition Highlight

  2. Summary Indicator Systems: e.g., AHA Heart Check, NuVal, Guiding Stars, Kraft Sensible Solution

  3. Food Group Information Systems: e.g., Whole Grain Council Whole Grain Stamp, ConAgra Start Making Choices

IOM has concluded that serving size, along with calories, saturated fat, trans fat and sodium are the most critical components to include on front-of-pack labeling.

IOM plans to complete Phase 2 of the study in 2011; this second phase will focus on consumer use/understanding and determining which systems best promote public health. The Phase 2 report will include recommendations for developing standardized FOP system(s).

GMA/FMI Initiative - Also in October, leading retailer and product manufacturer industry groups, Grocery Manufacturers Association (GMA) and Food Marketing Institute (FMI), joined forces to establish a new FOP nutrition labeling initiative. While still finalizing the details on technical and design elements, it is expected that food labelers will begin using this new system in 2011. The system from GMA/FMI will focus on "nutrient-dense" diets and "shortfall" nutrients.

Keeping You Current

NYC reports that six new companies have joined the National Salt Reduction Initiative

FDA and FTC issued separate warning letters to the same companies who have used caffeine as a food additive in alcoholic malt beverages

FDA announces a meeting on March 30-31, 2011, to discuss FD&C certified colors (i.e., Yellow 5, Yellow 6, Red 40) and behavior issues in children

From the Archive

Q&A's about FDA label components:

Is FDA approval of food labels required?

How can I make sure my label meets FDA regulations?

Which address to use on the signature line?

Expand your network in food labeling. Join the Food Label Community on LinkedIn

The tug-of-war between IOMs exclusive focus on "over consumption" nutrients (calories, saturated fat, trans fat and sodium) and GMA/FMI's focus on the "short fall" nutrients is clear. As the dust settles on FOP regulations, food labelers will likely have until at least January 1, 2014 (uniform compliance date) to adopt any new requirements.

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

In the last 4 months, we have profiled the five required components for every FDA regulated food label. In addition to Product Identity, Net Contents Statement, Nutrition Facts, and the Ingredient List, the last required component is what is commonly referred to as the Signature Line.

Signature Line

All packages are required to include the name, street address, city, state and zip code (or country and postal code if outside U.S.) of the responsible party. While the telephone number and website are optional, they cannot be used in lieu of the address. Note that the street address can be omitted if it is readily available in a local telephone directory (Google doesn't count).

  • Responsible Party The manufacturer, distributor, importer or marketer must be identified. If it is an entity other than the manufacturer, then a phrase such as "distributed by," "made exclusively for" or "imported by" must precede the signature.

  • Placement The Signature Line is placed on the information panel along with the Nutrition Facts and Ingredient List. These three components must be placed together without intervening material.

  • 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.

In summary, you can access a one page overview of all five FDA regulated label components here.

While the Country of Origin is not an FDA requirement, it is required by U.S. Customs for imported products and typically follows the signature line ("Product of Brazil," "Made in Mexico"). The actual country needs to be specified, not the continent ("Product of EU" is not acceptable).

Reader Q&A

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


When a product like Fruitabu or V8 vegetable juice says "contains a serving of fruit" or "contains a serving of vegetables" what does that mean? What methodology are they using, because when you look at the NLEA serving sizes or the USDA serving size for a fruit or vegetable, the calories, total sugar and fiber are inconsistent with how the product is labeled?
D.K., Pediatric Nutritionist, Connecticut


FDA does not define serving sizes for food groups (i.e., fruits, vegetables, grains). FDAs Reference Amounts (the NLEA serving sizes) are the amounts customarily consumed; they are defined for 135 product categories (i.e., breads, crackers, puffed cereals, high fiber cereals). These Reference Amounts do not necessarily correlate with serving sizes for food groups. Serving sizes for food groups vary depending upon which food group system you use: diet exchanges, Child Nutrition program information, USDA's MyPyramid information for a 2,000 calorie diet, or the NLEA serving sizes. 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, were pleased to provide information to address your food labeling needs.

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