Volume 15, Number 4 - April 2015

Hello Spring! We're pleased to bring clarity to the murky waters of net weight in this month's issue. You'll also find a helpful resource to understand daily values for vitamins and minerals. Read on and let us know if you have any questions – either through the Food Label Community on LinkedIn or by submitting a reader question for our most popular section: Reader Q&As.

In this issue you'll find:


"I am learning so much from the food labeling group on LinkedIn, led by your staff. Thank you!"

– Carol Long

Navigating the Waters of Net Contents

What's News in the Food Label Community

Reader Q&A: Daily Values for Vitamins & Minerals


Karen C. Duester, President

Navigating the Waters of Net Contents

The net quantity of contents statement is one of those things that sit squarely in the middle of several sources of information that are conflicting and confusing.

Code of Federal Regulations (21 CFR 101.105)

Public Law No. 102-329, August 3, 1992

FDA's 1993 Proposed Rule for Metric Labeling

FDA's Food Labeling Guide

Reader Favorites

One-page Summary of 5 Required Food Label Components

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Questions often surface about how to handle the various elements. We've outlined a few of the contradictions and then suggest an appoach.



Is metric labeling required?
Public Law requires the declaration of net contents in metric terms as well as U.S. Customary System terms and FDA's Food Labeling Guide confirms it, yet FDA has never written this into the Code of Federal Regulations.



Must the net contents statement be preceded by Net Weight or Net Volume?
The Code of Federal Regulations specifies that the net quantity of contents statement begin with the phrase Net Weight (or Net Wt) when stating net contents by weight, and makes the term Net Contents (or simply Net) optional for packages sold by volume or numerical count. However, FDA's 1993 Proposed Rule written to implement the Public Law does not include this lead-in requirement.


Declaring contents for packages between 16 oz and 4 lbs (for weight) and 1 pint and 1 gallon (for volume)
According to the Code of Federal Regulations, packages containing these amounts must include pounds and ounces as well as total ounces (for weight) and in the case of volume the largest whole unit (quarts, quarts and pints, or pints) with any remainder as fluid ounces or a decimal fraction of the pint or quart. However, the 1993 Proposed Rule written to implement the Public Law does not include this specification.

It would have been helpful to U.S. food labelers if FDA had continued with their rulemaking process and issued a Final Rule, then written the requirements into 21 CFR 101.105. While marketers often prefer a minimalistic approach, our guidance is to use the most conservative elements of each source despite the contradictions. For example, the declaration for a 24 oz. package would be:
NET WT 24 OZ (1 LB 8 OZ) 680g

What's News in the Food Label Community

Determining nutrition values for Nutrition Facts labels (16+ comments and 6+ comments)

Combination labels for multiple countries (8+ comments and 2+ comments)

Ingredient naming: Dried, Freeze-Dried, or Powdered? (10+ comments)

Product names using natural-type flavors (6+ comments)

Nutrition labeling for dog food (10+ comments)

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Reader Q&A

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


Is there an official list of U.S. daily values for vitamins and minerals that you can point me to please?  
D.H., United Kingdom, Consultant 


Yes, this can be found in 21 CFR 101.9. In addition, you can find a helpful one-pager that shows the differences between current and proposed regulations for U.S. Nutrition Facts Labels. More reader questions.

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