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Volume 17, Number 4 - April 2017

Greetings from Food Label News! This month we explore one of the most talked-about topics: when it's acceptable to group ingredients within the Ingredient Statement. Read on to learn the specifics for this widely enforced FDA regulation. You'll also read about the appropriate use and implications of using hangtags, a response to a reader's question. Please send us your questions and we'll be sure to provide answers either in the Food Label Community or future issues of Food Label News.

In this issue you'll find:

More About Ingredient Labeling:
When to Use Collective Names

What's News in the Food Label Community

Reader Q&A: Hangtags


"Your input was insightful, realistic and incredibly valuable. Thank you!"

– Amanda Berhaupt-Glickstein, MS, RD 
Rutgers University  


Karen C. Duester, President

More About Ingredient Labeling:
When to Use Collective Names

A common question to both Food Label News and the Food Label Community is when it's allowable to combine ingredients in the Ingredient Statement. It's a marketer's goal to list favorable ingredients as close to the top as possible. In some cases this is feasible, however it is more of an exception than the norm.


Reader Favorites

Beware: Warning Letters May Cost More Than You Think


FDA regulations require food labelers to list ingredients in descending order of predominance by weight in packaged foods. The name of an ingredient used in the Ingredient Statement must generally be a specific name and not a collective name. There are, however, several specific situations where collective naming is allowed. These include:

Ingredients with established common or usual names – Worchestershire sauce, mustard and tomato sauce are widely established products and therefore the common name may be used for the combined ingredients followed by individual ingredients in parentheses.

Ingredients with standards of identity – Bread, ice cream and French dressing all have standards of identity so listing individual ingredients in parentheses after the standard name is allowed.

Milk products – Different forms of milk such as concentrated milk, reconstituted milk and dry whole milk can be combined and listed with the shortened name "milk" without any parenthetical ingredients. The same concept applies to different forms of skim milk, cream, whey and buttermilk.

Egg products – Different forms of eggs such as dried whole eggs, frozen whole eggs and liquid whole eggs can be combined and listed with the shortened name "eggs" without any parenthetical ingredients. The same concept applies to egg whites and egg yolks.

Fat and oils – These can be listed collectively when they are part of a blend, for example, vegetable oil (corn, canola and soybean oil).

Fish protein ingredients in processed seafood products – This exception applies only when the manufacturer is unable to adhere to a constant pattern of fish species because of seasonal or other limitations of availability. For example, fish proteins (pollock, cod and/or pacific whiting).

Wax and resin on fresh produce – These coating ingredients require specific wording to accompany the collective name, for example, coated with beeswax and/or lac–resin.

Specific functional classes of ingredients can list the collective name in the Ingredient Statement followed by the individual types in parentheses. Examples include:



Leavening agents – Leavening (baking soda, monocalcium phosphate, calcium carbonate)


Yeast nutrients – Yeast nutrients (calcium sulfate and/or ammonium phosphate)


Dough conditioners – Dough conditioners (L-cysteine, ammonium sulfate)


Firming agents – Firming agents (calcium carbonate and/or calcium sulfate)

Flavors, Spices & Colors – Many of these can be listed by a collective name, however there are important exceptions and caveats. Stay tuned to Food Label News for more on labeling these important and often tricky categories.

Food labelers wishing to use collective naming should consult all applicable sections of the Code of Federal Regulations, starting with 21CFR101.4 and 21CFR101.22.

We often get specific questions about how to list combinations of nuts, fruits, grains and juices in the Ingredient Statement. The regulations do not allow collective ingredient labeling for ingredients like these, therefore, examples like the following are NOT allowed:


Nuts (almonds, peanuts, walnuts)
Dried fruits (cherries, blueberries, raisins)
Grain mix (oats, brown rice, quinoa)

Fruit juice concentrates (apple, grape, cherry)

FDA watches collective naming carefully. We only need to recall the FDA warning letter to KIND, LLC in 2015 citing that listing the collective terms "mixed nuts," "dried fruits" and "vitamins" as multicomponent foods and declaring the specific nuts, fruits and vitamins as sub-ingredients is not allowed.  

What's News in the Food Label Community

No artificial colors claim (8+ comments) and (9+ comments)

Vinegar standard in the EU (9+ comments)

Authorization for dietary ingredients (13+ comments)

Squid ink as color additive (9+ comments)

Vitamin A conversions (14+ 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.


Can I attach a tag to a jar of fruit spread since I do not have room for a conforming Nutrition Facts label? 
K.S., New York, Food Manufacturer


Yes, this is possible. If a manufacturer chooses to add label space for any purpose with a hangtag then this additional space is included in the total available space for labeling. This combined space determines the minimum type size requirements for all label components including the specific Nutrition Facts format to be used. In addition, the tag must adhere to the package throughout storage and shelf life conditions. Read more.


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