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

Volume 15, Number 8 - August 2015

Greetings from Food Label News. 'Tis the season for summer vacations and world travel. We join you around the world with a lead article about geographic references in product names. The Q&A this month is about FDA enforcement discretion for labels. Let us know what you think and other questions you may have. Be sure to catch the Reader Favorites, our most popular articles from issues past, focused on U.S. and Canada comparisons. Enjoy your summer!

In this issue you'll find:


"I recently discovered your cutting edge newsletter and find it to be an excellent source of food labeling information."

Jingying Yang  
Yale University  

Around the World in Product Names:
Using Geographic References in U.S. and Canada

What's News in the Food Label Community

Reader Q&A: Phase-in for Label Changes?


Karen C. Duester, President

Around the World in Product Names: Using Geographic References in U.S. and Canada

Asian Rice. French Bread. Thai Noodles. Vienna Sausage. When can you use geographic references in product names? Both FDA and USDA have requirements concerning geographic naming. Take note of the nuances that apply to your product.

Reader Favorites

Quick Food Label Comparisons: U.S. vs Canada


In U.S., FDA and USDA require that a product meet one of four conditions to use a geographic reference on the label:

Truthful representation of geographic origin. Noodles made in Thailand can be labeled "Thai Noodles." "Virginia Ham" is only acceptable for a ham produced in the state of Virginia.


An exclusive long-standing trademark or a name that is so fanciful, it's not generally understood to be a geographic reference. "Near East Rice" and "Moon Sausage" are examples.


A part of the name required by applicable Federal law or regulation, such as "Frankfurters."


A name that is generally understood to be a specific type or style of food or preparation rather than from a particular geography. "French Bread" and "Italian Dressing" are examples. For USDA, these terms must be qualified with the word "style" or "type" unless specifically approved as a generic term (e.g., "Genoa Salami").

To use a geographic reference on a product that does not meet the above guidelines, note:

FDA-regulated foods need to be qualified with the word Style as in "Asian Style Rice."

USDA-regulated foods need to be qualified with the word Brand along with a statement about where the product was made, such as "Milwaukee Brand Bacon, Made in Chicago, Illinois." The word Brand must be in the same size and style of type as the geographic term.

Regulations for use of geographic references in product names are similar in Canada. For example, a product named "New Orleans Jambalaya" is misleading if it did not originate from or was not last processed in New Orleans. In this instance, use of the word "Style" is required: "New Orleans Style Jambalaya."

Some special circumstances exist: 1) standardized product names - for example, "Pommes Fuji Apples" do not need to originate from Fuji, Japan, and generally do not; and 2) long-established trademarked brand names - for example, "Marque Vienna Brand Rye Bread / Pain de seigle" does not need to originate from Vienna, Austria.

21 CFR 101.18
FSIS Policy Memo 068
CFIA Guidance Document Repository

What's News in the Food Label Community

FDA Updates: More revisions for Nutrition Facts Labels (2+ comments) and Restaurant Menu Labeling extension (1 comment)

Transitioning to a regulatory position (9+ comments)

How much almond should be in almond milk? (9+ comments)

Can parsley be called "natural flavor"? (10+ comments)

Processing aids (8+ comments)

Join Food Label Community. Already a member, view Discussions.

Reader Q&A

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


My supplier changed one of the ingredients we use in our product, resulting in small changes to our ingredient statement and nutrition facts. Is there any phase-in period so that we don't have to discard the packaging we have in stock?  
L.E., Arizona, Cookie Manufacturer 


There is no phase-in period for new labels, as they must accurately reflect the contents of the package. However, under certain circumstances FDA will agree to enforcement discretion on a case-by-case basis. Read more.

What Matters in Food Labeling

Food Label News, now in its 15th year, is a monthly e-newsletter reaching over 9,000 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

2015. Food Consulting Company, Del Mar, CA. All rights reserved.