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Volume 15, Number 12 - December 2015

'Tis the Season from Food Label News! As the year comes to a close, we are excited to comment on FDA initiatives regarding use of the term natural and labeling guidance for genetically modified foods. You will also find an important Q&A about statement of identity and one of our reader favorite articles: 5 food label bloopers. Wishing you happiness, good fortune, and the health to enjoy it all. Cheers!

In this issue you'll find:


"Thanks for making this process really smooth. I so appreciate it, as the label is one area that small food companies like myself have a hard time with. But you totally made it manageable. Your reports were the best, clearest, and most helpful I have ever had in any territory."

– Glenn Elliott  
King of Kiwi  

Welcome News in the World of Food Labeling

What's News in the Food Label Community

Reader Q&A: Statement of Identity


Karen C. Duester, President

Welcome News in the World of Food Labeling

Last month's news from FDA was a welcome development: opening its rulemaking process for use of "natural" on food labels and labeling guidance for genetically modified foods.

Reader Favorites

5 food label bloopers


While the USDA already has a policy on natural, not since the early 1990s has FDA revisited their position on either natural or genetically modified foods. The food industry would benefit from a clear and unified policy as well as consistency between government agencies.

Why is FDA moved to act now? We cannot be certain, however there is deepening controversy over the use of bioengineered foods and the term natural on food labels – both of which have been the focus of class action lawsuits, state legislation, and citizen petitions. Judges have been asked to determine if consumers have been misled when a food labeled natural contains ingredients derived from bioengineered plants or certain processing methods. While FDA has now issued final guidance on the voluntary labeling of foods that do and do not contain genetic engineering (GE), many key questions remain unanswered. For example: Can a food containing an ingredient derived from a GE plant still be natural? Should agricultural practices such as bioengineering be factored into the definition of natural?

FDA's initiative to investigate these questions and their follow-on answers may provide much needed guidance for the food labeling industry. We applaud this effort and invite our colleagues to submit their comments to FDA by February 10, 2016 and join the discussion in the Food Label Community.

Our takeaway: It's refreshing that FDA has opened the dialogue on this topic. As consultants to the food industry, we have urged caution to-date when using the term natural, given the potential risk. Our approach is to advocate for alternative ways to communicate key marketing messages without using the term natural until the current environment shifts.

What's News in the Food Label Community


FDA Actions: Comment period for "natural", Final Guidance for GE foods, GE Salmon: Safe to eat, Q&As on Fortification Policy, Proposed Rule for gluten-free fermented, hydrolyzed, and distilled foods


Labeling on small packages (13+ comments)


Statement of Fact and Disclosure Statement (30+ comments)


Using "pure" and "simple" on food labels (12+ 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.


I know there are requirements for the "statement of identity" but what part of the product name counts as the "statement of identity"? I can’t find a definition for that term.  
M.G., Minnesota, Food Start-up 


21 CFR 101.3 defines the identity labeling of food in packaged form. The Principle Display Panel (front of package) is required to include as one of its principle features a statement of the identity of the commodity. The statement of identity is either the name of the standardized food or an appropriately descriptive product name. Read more in a previous article from Food Label News.

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