Food Label News ArchiveFood Label News SubscriptionsNutritional Analysis Food Labels - Food Nutrition Facts LabelsFood Consulting Company: Nutrition-Labeling-Regulatory

Volume 13, Number 10 - October 2013

Greetings from Food Label News. When it comes to what matters in food labels, it's both the black and white regulations as well as nuances that count. Be sure to read this month's article to understand some of the trickiest food label rules and case studies about how others have achieved regulatory compliance. We also feature our popular Reader Q&A focused on gluten-free. Wishing you an abundant harvest this Fall.

In this issue you'll find:


" I couldn't do my job without your newsletter. It's invaluable."

– Kimberly Lord Stewart

The Trickiest Food Labeling Rules

Client Highlights - Food Labels and Regulatory

Reader Q&A: Are Spices Gluten Free?

What's News in the Food Label Community


Karen C. Duester, President

The Trickiest Food Labeling Rules

Deciphering food label regulations that are black and white is one thing. Navigating the shades of gray with seemingly conflicting regulations is another. It can be tricky to blend many sources of information such as public laws, multiple sections of the U.S. Code of Federal Regulations (CFRs), FDA and USDA-FSIS guidance, as well as industry best practice. Food labelers must integrate a variety of factors to ensure 100% regulatory compliance. Here are a few tricky ones:


Product Identity – The starting point is to understand if a food meets a specific Standard of Identity. For non-standardized foods, understanding naming requirements and rules around flavor and other qualifiers are also important.


Net Contents Statement – There are several inconsistencies between the Public Law (P.L. 102-329) and Code of Federal Regulations (21 CFR 101.105) related to net contents labeling. In addition, there are differences in industry practice for USDA-regulated foods and FDA-regulated foods. The majority of the inconsistencies relate to the requirements for metric labeling, although there are others.


Country of Origin – There are both mandatory and voluntary statements and policies about the country of origin, including regulations under NAFTA and COOL. Federal agencies such as FTC, USDA-AMS, USDA-FSIS, FDA, and other entities all have requirements that confound the issue.

What's News in the
Food Label Community


Food Labeling Modernization Act of 2013 introduced in U.S. Congress


Insights on Foods for Special Dietary Uses


Oldways issues scientific consensus statement on Glycemic


USDA updates sugar values for cream products

• Unintended presence of soy and Canadian allergen labeling

Connect with other food labelers on LinkedIn

Reader Favorites

Due Diligence with Database Nutrition Analysis: Guidebook and Rules of Thumb


Search answers to food label questions

These and other issues are frequently posed in the Food Label Community, the virtual water cooler for food labelers. For example, there has been discussion of declaring spices that also function as colors, reporting trans fat in the Nutrition Facts when the total fat is zero, disclosure vs. disclaimer statements, and what counts as an incidental additive. See the Food Label Community on LinkedIn to join the conversation.

Client Highlights - Food Labels and Regulatory

Food label regulations can be challenging for start-up companies, established multi-national retailers, and importers alike. Those involved in food labels can learn from how other companies manage the nuances of food label regulations.

Start-up company launches novel beverage concept - Navigating food labels and Nutrition Facts for a new-to-the-world beverage brand in a highly competitive industry is no easy task, especially for a young, start-up company. With an outsourced regulatory strategy, they were able to keep laser focus on core competencies: building, marketing and selling their new brand. Read the case study.

Consistent food labels and Nutrition Facts across a major national retailer's private label vendors - Managing a large, private label brand that spans many categories has its challenges. Ensuring that nutritional information and food labels are consistent, accurate, and compliant across hundreds of suppliers and products is essential. Read the case study.

Americanizing foreign packaging – For a foreign foods importer, understanding U.S. regulations is not trivial. This food importer overcame food label challenges and ensured that their products easily passed through U.S. Customs and FDA Inspections at the border. The result was a successful U.S. introduction and 100% regulatory compliance. Read the case study

A special invitation: What's your process to ensure 100% regulatory compliance? Submit your company for consideration and if chosen you’ll be featured in Food Label News. An excellent way to showcase your work both internally and for the food label community. Click here.

Reader Q&A

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


A client with celiac disease who is carefully following a gluten free diet has concerns about ingredient labeling when he sees the word "spices". Does he need to avoid foods that have "contains spices" on the ingredient label?
J.B., Indiana, Hospital


Spices are by definition gluten-free. A consumer following a gluten-free diet can feel comfortable eating food that contains spices, provided the manufacturer is reputable and has followed all FDA labeling requirements. If in doubt, a consumer can always call the company's customer service line to verify. Read more.

What matters in food labeling

Food Label News, now in its 13th year, is a monthly e-newsletter reaching over 7,500 subscribers around the world. We welcome your colleagues to subscribe for news and insights about food labels:


Your virtual food label partner

Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling, and regulatory support for more than 1,500 clients worldwide.
Our guarantee: 100% regulatory compliance. Contact us for the help you need now.

You may reprint all or part of this newsletter provided you attribute it to Food Label News and include a link to

© 2013. Food Consulting Company, Del Mar, CA. All rights reserved.