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1213 Bakers Way

P.O. Box 3999
Manhattan, KS 66505-3999
Phone: 785/537-4750

Andre Biane
President & CEO

Kathryn Mayes
Director of Marketing

Melissa Kirkwood
Media Relations

What Exactly Am I Eating?


While the components of a most current information for food products is pro-
vided to inform the consumer, avoid possible regu-
food product label may seem lation violations, and prevent products from being
fairly simple, it is important to subject to recall or disciplinary action.
understand the requirements Although FDA regulates most food products,
USDA is in charge of beef, poultry, and pork regu-
that have to be met to comply lations. USDA regulations are very similar to FDAs,
with regulations. but there are some differences. Be sure you reference
the proper set of regulations for your products.
By Elaine Meloan

he first thing a consumer sees when pur- The Principal Display Panel (PDP) is the section of
chasing food at the supermarket is the prod- the label the consumer most likely sees when the
uct label. Many decisions are made based package is on display on retail shelves. The area of
AIB International on the information provided on the label, and it the PDP is determined by the size and shape of the
empowers clients is the responsibility of the manufacturer to ensure package.
worldwide to elevate
all information is available and accurate. While the The Information Panel (IP) is the section imme-
their food safety and
components of the label seem fairly simple, it is diately contiguous and to the right of the Principal
production process

capabilities by
important to understand the requirements that Display Panel. If the panel to the immediate right
developing and delivering have to be met to comply with regulations. of the PDP cannot be used, the panel to the right of
application-oriented The goal of a labeling program is to ensure all that panel should be used as the IP. Reasons to not
learning, consulting, and food labels comply with government regulatory use the panel directly to the right of the PDP could
value-added services. standards. This is to ensure that the correct and be insufficient space for the required information,

AIB UPDATE May/June 2016 19


or the panel containing packaging seals that be labeled as artificially flavored. mineral oil. Keep in mind, if an ingredient
are impossible to print on or may make the contains an allergenic substance, the ingre-
information unclear. INGREDIENT STATEMENT. The ingre- dient cannot be categorized as incidental,
Information that is required on the PDP dient statement is the list of all the ingre- and must be listed in the statement.
and any alternate PDPs are the identity dients used in a product. This statement is Allergens are a very important part of
and net quantity of the contents. Other required if a food is comprised of two or food labeling and their presence must be
information that is required on the PDP more ingredients. The ingredients are to be listed. The major food allergens in the U.S.
or the IP are the ingredient list, includ- listed in order of predominance by weight include:
ing allergens; statement of the responsi- of the ingredients used. This means the Milk
ble company; and nutrition (if for retail ingredients must be listed in order of the Eggs
sale). Other information may be required most used to the least used in that product. Soybeans
depending on the nature of the food and Ingredients used at 2% or less do not have Peanuts
other information on the label. For exam- to be listed in order of predominance if Wheat
ple, a claim may need additional support- they are preceded with the statement con- Tree nuts
ing information. tains 2% or less of _______. Fish
The declaration of artificial colors, ar-
STATEMENT OF IDENTITY. The state- tificial flavors, and chemical preservatives CRUSTACEAN SHELLFISH. In the case
ment of identity is the name of the type must be included in the statement. The of tree nuts, fish, and crustacean shellfish,
of food in the package. For example, if function of all chemical preservatives must the type or species must be declared. There
the product is bread, it must be named be declared unless they are natural preser- are two ways an allergen can be declared: If
as such. This name may not be false or vatives such as vinegar, cultured whey, or the allergen is listed in plain English by its
misleading to the consumer in any way. If raisin-juice concentrate. food allergen name in the ingredient state-
this food is an imitation of an- ment, a supplemental statement
other food, it must be labeled is not necessary. If the common
that way. If there is a standard or usual name of the ingredient
of identity for the product, it does not disclose the allergen
must meet the requirements of by the food allergen name, you
that standard. may list the food allergen name
A standard of identity is a set in parentheses following the
of criteria that is created to es- common or usual name of the
tablish the ingredients that are ingredient. For example, whey is
required or allowed in a certain a milk product, so it would be
type of food product for it to listed as whey (milk).
be named as such. Examples of Secondly, a company may
some products that have stan- choose to use a Contains
dards of identities are enriched statement immediately follow-
bread, flour, sour cream, and ing the ingredient statement.
mozzarella cheese. If a Contains statement is
Most food products do not With many consumer buying decisions based on the product label, used on a food label, the names
have a standard of identity. If manufacturers must ensure all information is available and accurate. of all the food sources of the ma-
there is no standard of identity jor food allergens used must be
for a product, the common name must be Groups of ingredients that may be par- declared. For example, if whey and natural
used. This is the name commonly known enthetically listed within the statement are flavor containing almonds are declared in a
and recognized by consumers. Examples of leavening agents, yeast nutrients, dough products ingredient statement, the Con-
common or usual names are crackers, cook- conditioners, firming agents, and fats or tains statement on the label must iden-
ies, and cereal. oils. tify the sources of the allergens. It would be
Flavored products also have requirements Incidental additives do not have to be listed as follows: Contains milk, almonds.
that must be met. Naturally flavored prod- listed in the statement. Incidental additives The Contains statement must be im-

ucts do not always have to be designated as are defined as substances that are present at mediately after or adjacent to the ingredient
naturally flavored. However, the natural insignificant levels and have no function in statement in the same font size as the ingre-
flavor of a product must be identifiable for the finished product. The term insignifi- dient statement.
that product to be named with that flavor. cant level is not defined and is up for indi-
If a product obtains any of its characteriz- vidual interpretation. An example of an in- NET QUANTITY OF CONTENTS. The
ing flavors from an artificial flavor, it must cidental additive is a processing aid, such as Net Quantity of Contents is the amount of

20 May/June 2016 AIB UPDATE


food in the package. That is, the amount Sodium rules for large discrete units.
of the food itself excluding the package. Total Carbohydrates Large discrete units are declared with
For retail products, the net quantity must Protein consumer friendly fractions. These in-
be declared in avoirdupois (inch-pounds) There are several exceptions to the stan- clude 1/2, 1/3, 1/4, 1/5, 1/6, or a smaller
and metric units. Typically, the inch-pound dard format. However, there are strict fraction that can be found by dividing one
declaration is listed first, with the metric guidelines on how and when they are to of the previous fractions by 2 or 3. These
following in parentheses. For example, if a be used. These alternate formats include fractions are most commonly found on
packaged food is 12 ounces, its net quan- simplified, tabular, linear, dual listing, dual foods such as pies, pizzas, and cakes. The
tity would be listed as 12 oz. (340 g). For language, aggregate, and food for children serving size for this type of product would
inch-pound units the remainder of a unit formats. be found by dividing the total weight of the
can be declared as a common fraction, dec- product by the RACC and finding the clos-
imal fraction, or as the smaller unit (e.g., THE RACC. FDA has created a way in est allowed division.
one and one-half pounds would be declared which serving size is determined based on
as 1-1/2 lbs., 1.5 lbs. or 1 lb. 8 oz.). Met- the amounts normally consumed in a sit- BULK PRODUCT. Examples of non-dis-
ric declarations may only use decimal frac- ting: Reference Amount Customarily Con- crete bulk products are flour and sugar.
tions, if needed. For products declared by sumed (RACC). Serving sizes are declared They are declared in household units that
weight, you must include the phrase net using household measures and are calculat- are closest to the RACC, such as a cup or
weight but no phrase is needed for volume ed differently for discrete units, large dis- tablespoon. For example, the RACC for
measurements. crete units, non-discrete bulk products, and flour is 30g. If the manufacturer found that
single-serving products. 1/4 cup of flour consistently weighed 28g,
RESPONSIBLE PARTY. A statement of Household measures are defined as cups, it would be declared as 1/4 cup (28g).
responsible party must be located on the tablespoons, pieces, slices, and ounces that A package is considered to be a single
PDP or IP. The statement must contain the are commonly used in the home and are fa- serving if it contains less than 200% of the
name of the party responsible for the label- miliar to the consumer. In the declaration RACC for that product. However, if the
ing, be it the manufacturer or distributor, on the label, the common household mea- food has a RACC of 100g (or ml) or more
and a current address. If the company list- surement should be followed parenthet- and the contents are between 150 to 200%
ed is not the manufacturer, the statement ically with the metric weight or volume. of the RACC, the package can be declared
should be qualified with distributed by, For example, a cup of food weighing 245g as 1 or 2 servings.
manufactured for, or some other equally would be declared as: 1 cup (245g). There are several exemptions from nutri-
informative statement. The address must Discrete units are products such as sliced tion labeling. The following do not have to
contain the street address, city, state, and bread, cookies, individually packaged ce- provide nutrition labeling:
zip code. The street address may be omitted reals in a multipack, or similarly packaged Bakeries and delis that primarily pre-
if the responsible party can be found in a products. If the product weighs 50% or less pare a food on-site.
local phone book or city directory. than the RACC, serving size is determined Food distributed to foodservice or
as the number of whole units most closely restaurants for further preparation.
NUTRITION FACTS. The Nutrition Facts approximating the RACC. For example, Foods that provide no significant nu-
Panel can take on many formats. The stan- the RACC for bread is 50g, so if a slice of trition, such as plain coffee or tea.
dard format, which applies to most packag- bread is 22g, you would have to declare two Food sold in bulk or for further pro-
es, must be used unless the package meets slices as a serving. cessing.
the definition of an exception. Nutrition If the product weighs more than 50%, Additionally:
facts must be printed in black or in one but less than 67% of the RACC, the man- Fruits, vegetables, and fish are under a
color that can be easily read, and must be ufacturer may choose between declaring voluntary nutrition labeling program.
printed on a white or neutral background one or two units as a serving. So if a slice FDA provides the nutrition values for
so as not to distract from the required in- of bread weighs 28g, the manufacturer may the top 20 in each group. food that has
formation. The type style must be easy to choose either one slice or two slices as a no significant nutrition.
read, and contain both upper and lowercase serving. Small businesses do not have to have
letters. The following statements must be Finally, if the product weighs 67% or nutrition information on their pack-
bolded: more of the RACC, but less than 200%, ages if they meet one of the two ex-
Nutrition Facts the serving size would be one unit. For emptions. First, if the business sells di-
Amount per serving example, an 84g muffin would be about rectly to a consumer and has total sales
% Daily Value* 153% of its 55g RACC. So, the entire muf- of less than $500,000 or food sales less
Calories fin would be declared as a serving. Products than $50,000, the business is exempt.
Total Fat over 200% of the RACC may be declared The second exemption is item specific:
Cholesterol as a single serving or divided based on the if a company employs fewer than 100

AIB UPDATE May/June 2016 21


full-time employees and sells less than previously mentioned in conjunction with
100,000 units of a food, that food is nutrient content claims also affect health
exempt from nutrition labeling. claims. If the prescribed levels of any of the
negative nutrients are exceeded, the food
However, the exemption is negated for is basically disqualified from making many
retail foods if any nutrition information of the approved health claims.
is on the package or any claims are made Approved health claims include the rela-
about nutrients. Additionally, if a compa- tionships between:
ny wants to include nutrition on foods that Calcium and osteoporosis.
would normally be exempt, it may, but the Lipids and cardiovascular disease.
same rules for formatting of the nutrition Dietary lipids and cancer.
panel must be followed. Again, for retail Sodium and hypertension.
packages, if they include a nutrient claim Soluble fiber from oats, psyllium, and
on the label, the nutrition panel is then re- barley and heart disease.
quired to be present to support the claim. Folate and neural tube defects.
Sugar alcohols and dental caries.
CLAIMS. Claims are regularly found on FDA has defined the terms that are regulated Soy protein and coronary heart disease.
packages. FDA regulates claims, and no for use in claims, including that of light/lite, Plant sterol/stanol esters and coronary
claim may be made on a package without which is limited primarily to calories and fat. heart disease.
the agencys approval or acceptance. Nu-
trient content claims describe the level of a Regulations require that the presence ON THE PLANT FLOOR. Verification is an
nutrient found in a product. The two types of a large amount of a negative nutrient important step in the labeling program. Af-
are explicit and implied claims. in a food be disclosed on the label, if the ter each print run, receiving personnel must
Explicit descriptors are those that clear- label also contains a claim about another verify labels to ensure the correct informa-
ly define the claim. An example would be nutrient. The disclosure statement would tion has been printed. When brought to the
Cholesterol Free, which clearly means be similar to the following: See nutri- packaging line, personnel must verify that
that no cholesterol is present. Implied tion information for [negative nutrient(s) the correct label is being used.
claims are less specific, and can be up to that exceed specified levels] content. The Employees responsible for destroying
interpretation. A claim such as High in negative nutrient levels are based on the obsolete labels must be educated about
Oat Bran, implies the food is an excellent RACC amount of the food and the serving the risks involved. It is not enough to sim-
source of fiber and should meet the defini- size weight for the labeled food. However, ply discard obsolete labels. Each company
tion of that claim. meals and main dishes have different levels. needs a written procedure for disposing of
FDA has defined the terms that are reg- The following are the disclosure levels for labels to ensure that they are not used in-
ulated for use in claims. The nutrients or general foods: correctly. Furthermore, labels that are cur-
foods with which the terms may be used in Total fat 13.0g rently being used at the facility should be
conjunction also are defined, including: Saturated fat 4.0g stored in a secure location to prevent inten-
Free can be used with sodium, sug- Cholesterol 60mg tional misuse.
ars, calories, fat, and cholesterol. Sodium 480mg
Very low can be used with sodium Relative claims are those that compare a SUMMARY. FDA and USDA regulate food
only. level of a nutrient in one food to the level labeling to ensure that consumers are in-
Low can be used with sodium, calo- in another food. Terms used include light, formed. Its critical that food labels comply
ries, fat, saturated fat, and cholesterol. reduced, less, more, or modified. Packages with applicable standards and regulations.
High/good source can be used with with these claims must contain the quan- Before products leave your plant, make sure
any nutrient with an RDI or DRV. titative amount for the nutrient in both youve correctly listed the principal display
Reduced can be used with sodium, foods, usually displayed in a table. The and information panels, statement of iden-
calories, fat, saturated fat, and choles- package must also contain the percent of tity, ingredient statement, net quantity of
terol. change of the component mentioned in the contents, responsible party, nutrition facts,
More can be used with fiber, pro- claim. claims, and other label statements to avoid

tein, vitamins, and minerals. Health claims provide information about legal ramifications and to ensure youre de-
Less/fewer can be used with sodium, the relationship between a nutrient or in- livering the most accurate product informa-
calories, fat, saturated fat, and choles- gredient in a food and a health-related con- tion to your consumers.
terol. dition. The claim may be explicitly made
Light/lite limited primarily to calo- or may be implied by the use of a symbol The author is Manager, Food Labeling, AIB
ries and fat. such as a heart. The disclosure nutrients International.

22 May/June 2016 AIB UPDATE