Food label nutrition facts – All about front-of-pack nutrition facts labeling

By Karen Duester | Published: July 31, 2012

When it comes to food label nutrition facts, front-of-pack is becoming a billboard for not only claims but nutrition facts as well. While there have been several attempts over the past several years to create a standard food label nutrition facts front-of-pack system (FOP), two have emerged recently that merit our attention: 1) Institute of Medicine (IOM) long-awaited report for food label nutrition facts on the FOP; and 2) GMA/FMI Facts Upfront food label nutrition facts for the front-of-pack FOP labeling scheme.

1. IOM’s long-awaited guidance for FOP food label nutrition facts
The Institute of Medicine (IOM) released its long awaited Phase II report in October 2011 that included recommendations for FOP labeling for food label nutrition facts. These food label nutrition facts recommendations were intended to help consumers choose healthier foods to prevent the most common chronic diseases (high blood pressure, heart disease, diabetes and obesity).

The report calls on FDA/USDA to develop, test and implement a single, standard FOP symbol system to appear on all food label nutrition facts on the FOP and be actively promoted to industry, consumers and other stakeholders. This food label nutrition facts symbol system includes “nutrients to limit” (calories, saturated and trans fats, sodium, and added sugars).
Click here to see the IOM’s recommendation for FOP: http://www.factsupfront.com/aboutTheIcons.html

Highlights for FOP food label nutrition facts

• Use of a ranking system (points) on the FOP food label nutrition facts to indicate a product meets qualifying criteria for saturated and trans fats, sodium and added sugars.
• No points on the FOP food label nutrition facts given to product categories that significantly add sugars (sugars, sweets, and beverages) or exceed threshold limits for any of the critical nutrients.
• While the FOP food label nutrition facts recommendations are for retail foods (packages and shelf tags), IOM hopes they will also be implemented for food label nutrition facts for foods sold in restaurants, food service, and other venues.

2. GMA/FMI’s industry direction for FOP food label nutrition facts

Not long before the IOM recommendations were released, Grocery Manufacturers Association (GMA) and the Food Marketing Institute (FMI) announced Facts Up Front, originally introduced as Nutrition Keys, a voluntary FOP food label nutrition facts system. Facts Up Front features information about both “nutrients to limit” (calories, saturated fat, sodium and sugar), as well as “nutrients to encourage” (potassium, fiber, protein, vitamin A, vitamin C, vitamin D, calcium and iron.) This is contrasted with IOM’s recommendations for FOP food label nutrition facts system that does not include “nutrients to encourage”.

Click here to see GMA/FMIs Facts Up Front: http://www.factsupfront.com/aboutTheIcons.html

How will FDA/USDA use these FOP food labels nutrition facts systems?

Neither of these systems add any new requirements for those who manage FOP food label nutrition facts. Industry is voluntarily adopting the GMA/FMI system and graphic as it has begun appearing on more and more package labels. Until FDA/USDA issues FOP food label nutrition facts regulations based on the IOM report or other recommendations, the GMA/FMI voluntary system seems likely to prevail. Any new regulations or guidance that FDA or USDA would issue could take several years to publish and/or become law.

Front-of-pack: a billboard for benefits
Still unclear about front-of-pack guidance for food label nutrition facts? Have an opinion to share? Join the discussion in the Food Label Community www.foodlabels.com/linkedin/community  on LinkedIn.

About the author
Karen C. Duester, President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, and food nutrition facts labels, and food labels regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com.

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Food label nutrition facts – 5 Food label mistakes rookies make

By Karen Duester | Published: July 22, 2012

For food label nutrition facts, the FDA has very specific requirements for products they regulate, including what must be present within the food label nutrition facts and what is not allowed. It’s not news to those of us in the food label industry that each line within the food label nutrition facts is highly regulated.

What to look for to right food labels gone wrong
As the largest provider of contract food label consulting worldwide, we see a lot of companies doing it right – and we also notice some common food label nutrition facts mistakes. These nutrition facts mistakes pose a concern for regulators and consumers alike, as they can call into question the accuracy of every other element of the food label.

Don’t get caught with one of these rookie moves on your food labels and food label nutrition facts:
1. Incorrect rounding on food label nutrition facts – If you pick up a package that indicates 244.1 calories within the food label nutrition facts, it’s a dead give-away.
2. Incorrect formatting for the food label nutrition facts – You can’t get creative. Lines, bars, fonts, spacing and type styles come with tight specifications for food label nutrition facts.
3. Incorrect serving size on the food label nutrition facts – It is not an option to choose your serving size so that the resulting calories or fat look more attractive on your food label nutrition facts. You must follow the “reference amounts customarily consumed” for ALL food label nutrition facts.
4. Food label ingredient statements that are too long – Salt is salt is salt. A food label composite ingredient statement that adds all like ingredients is cleaner and more consumer-friendly.
5. Listing a multi-component ingredient as a single ingredient on a food label – Ketchup is created from multiple ingredients and each of these ingredients must be listed within the food label ingredient statement. You can choose to group like ingredients together on the food label or use parentheses to declare sub-ingredients.
6. Food label claims can be the trickiest part of food label compliance. Words like “healthy”, “low fat” and “high fiber” cannot be used at will and can only be used when the food label nutrition facts has a specific nutrient profile and meets all other regulatory requirements.

Food label nutrition facts quick guides to the rescue
To keep you in the clear, make sure every element of your food label and food label nutrition facts complies with FDA regulations. We’ve prepared a one-pager quick reference, and a series of examples for food label nutrition facts. Or, review the Silliker Nutrition and Health Claims Regulatory Guide, co-developed with Food Consulting Company. These resources will help you go from rookie to quick study and ensure 100% regulatory compliance on your food label nutrition facts.

About the author
Karen C. Duester, President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, and food nutrition facts labels, and food labels regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com.

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Food nutrition facts labels – “Made in the USA”

By Karen Duester | Published: July 10, 2012

Creating food nutrition facts labels and other label copy to comply with the “Made in USA” standard is not as straightforward as it may seem. There are regulations that make clear when and where you can say “Made in the USA” on food labels. When ingredients are sourced and manufacturing takes place in the USA, the impact for food nutrition facts labels and other label copy is pretty straightforward. But what are the implications for food nutrition facts labels and other label copy if ingredients are foreign sourced but the formula is manufactured in the USA? What if the majority of food components are from the USA?

Clear and informative food nutrition facts labels“Made in USA” is considered to be a marketing claim that applies to products and food labels, advertising, and other promotional materials. FTC (and not FDA) regulates this U.S. origin claim to prevent deception and unfairness on food labels and packaging in the marketplace.
To include “Made in USA” or “Product of USA” on food labels, FTC has required that the product be “all or virtually all” made in the U.S. The term U.S. includes the 50 states, the District of Columbia, and the U.S. territories and possessions, such as Puerto Rico, Guam or the Mariana Islands.

When products contain foreign components but are packaged or assembled in the U.S. the concept of “substantial transformation” becomes relevant for food nutrition facts labels and other food label copy. U.S. “Substantial transformation” occurs when a new article emerges with a new name, use and character. For example, coffee beans that are imported from Brazil but ground, flavored and packaged in the U.S. can include “Product of USA” on the food label.

Here are some additional nuances to keep in mind when contemplating the “Made in USA” or “Product of USA” claim for your food labels. See FTC’s “Complying with the Made in USA Standard” for more information.
• “All or virtually all” means that all significant parts and processing that go into the product must be of U.S. origin. The product should contain no – or negligible – foreign content.
• The food product’s final processing must take place in the U.S.
• Consider the overall impression of the food labels or advertising. Symbols or images such as the U.S. flag or outline of the U.S. map may imply a made in the U.S. claim.

Separate and distinct regulations for food nutrition facts labels in Canada
The Canadian corollary to “Made in USA” and “Product of USA” is “Product of Canada” on food labels is covered by separate Canadian regulations. “Product of Canada” can be claimed on food labels if all major ingredients originate in Canada and non-Canadian ingredients total less than 2%. Canadian products of domestic and foreign materials may say “Made in Canada from imported ingredients” or “Made in Canada from domestic and imported ingredients” (but cannot claim “Product of Canada” on the food label) provided the last “substantial transformation” of the product took place in Canada. Other truthful Canadian processing claims such as “packaged”, “prepared”, “processed”, “refined”, “roasted”, “distilled”, “canned” may also be made.

About the author
Karen C. Duester, President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, and food nutrition facts labels, and food labels regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com.

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Food nutrition facts labels – Reducing your regulatory risk

By Karen Duester | Published: June 21, 2012

When it comes to food nutrition facts labels, our mission in the food labels industry is to communicate food and nutrition information to consumers appropriately. While there are clear and specific regulations governing what we can and cannot do on food labels, there are also shades of gray. How do you navigate the ambiguities?

How to negotiate tricky food label challenges
Consider for example a couple of potentially tricky scenarios. How they were resolved provides a bit of insight into the creative approaches companies adopt to ensure 100% regulatory compliance on their food nutrition facts labels.

Scenario #1: New-to-the-world beverage depends on food nutrition facts labels to support its positioning in the highly competitive industry.
Vitality Distributing, a young start-up company, recently launched a new brand, the first of its kind – Avitae Caffeinated Water. Positioned as a healthier alternative to soda, Avitae needed to carved out a unique space in the fiercely competitive beverage industry and its food nutrition facts labels had to support it. This brand was the first-ever combination of natural caffeine and purified water and FDA compliance with food label regulations was absolutely essential to its successful launch. The most scrutinized part of the label is often the food nutrition facts label. Vitality Distributing got counsel on the nuances and tradeoffs for achieving brand goals and regulatory compliance. Their ultimate strategy included creating a pre-emptive white paper to address potential FDA concerns along with a food nutrition facts label that sported an entire panel of 0’s.

Scenario #2: Is there a difference between “0g trans fat per serving” and “Zero Trans Fat”?
These two statements are in fact different. “0 grams trans fat per serving” is a factual statement and is allowed on food nutrition facts labels provided the information is truthful and not misleading. If the food contains less than 0.5 gram (1/2 g) of trans fat per serving, this statement is allowed. By contrast, “trans fat free” cannot be used on food labels. Per FDA regulations the term “free” is a nutrient content claim and these claims apply only to nutrients or dietary substances that have an established daily value; no daily value has been established for trans fat. Further, food labelers need to know that existing regulations disallow claims about trans fat using the following terms: Zero, No, Without, Trivial Source of, Negligible Source of, Dietarily Insignificant Source of, Low, Little, Few, Contains a Small Amount of, Low Source of, Reduced/Less, Lower, Fewer, and any synonyms of these words.

Food nutrition facts labels – art or science?
Understanding regulation nuances for food nutrition facts labels is a skillful endeavor. There are many go-to sources that offer direction, including U.S. Code of Federal Regulations, FDA’s Food Labeling Guide, CFIA’s Labelling Guide, Silliker Nutrient and Health Claims U.S. and Canadian Regulatory Guide. In addition, Food Label News, a monthly e-newsletter published by Food Consulting Company is well read for what matters in food labeling.

An alternative approach is to work with a food nutrition facts labels regulatory consultant whose role is to understand the regulations and guide the development and approval of your food nutrition facts labels accordingly. Companies such as Vitality Distributing mentioned above chose Food Consulting Company as their virtual food label department. In this role, the consulting company starts with an understanding of the business needs and with an intimate understanding of the regulations, providing counsel based on research of other published government guidance, industry best practices and actions by consumer interest groups. With that background, consultants such as Food Consulting Company reach out to all client constituents including Regulatory, R&D, Marketing, Legal, and Management — and in many cases negotiate between departments to find creative solutions for food nutrition facts labels that achieve business goals.

Details and nuances matter
Solving food nutrition facts label challenges with inter-departmental negotiations can be a crazy process. Here are some tips to preserve sanity during the process of understanding and parsing nuances in regulations for food nutrition facts labels.
• Be clear about objectives and what is important to each department
• Step back and make sure there is no chance of misleading the consumer
• Get outside counsel for an independent opinion on food nutrition facts labels
• Be open – there’s more than one way to resolve the issue. For example, a minor reformulation may be all that’s needed to rectify a potential food label regulatory issue
• Consider a partner who can contact the FDA anonymously to investigate nuances on your behalf
• Successful resolution is largely a function of people skills and “can-do” attitude to resolve inter-departmental conflict on food labels

About the author
Karen C. Duester, President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, and food nutrition facts labels, and food labels regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs. The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com.

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Nutritional analysis, food labels: How to avoid being detained at the border

By Karen Duester | Published: June 7, 2012

When it comes to nutritional analysis, food labels, sailing through U.S. and Canadian customs is easy, until it’s not. While both the U.S. and Canada participate in Codex, the international body that provides guidance on food safety and food label issues, each country is responsible for its own set of food label regulations. Unfortunately for those responsible for nutritional analysis, food labels, these regulations are not co-developed. Therefore, despite the two countries long history of harmonizing requirements for food labels, we cannot simply add French to a U.S. label and expect the product to effortlessly pass through Canadian customs.

Food Labels: similarities and differences

The U.S. and Canada have different requirements for food labels and it is not possible to have food labels that satisfy the regulations in both countries. While bilingual (English/French) is an obvious Canadian requirement, there are several other country-specific requirements that span nutritional analysis, food labels formatting, and formulation. One simple example is nomenclature for Nutrition Facts — “Panels” in the U.S., “Tables” in Canada.

A sampling of other differences between the countries’ nutritional analysis, food labels include:
• Rounding rules – In Canada, trans fat has tighter reporting requirements than in the U.S.
• Units for reporting nutrients – U.S. uses International Units (IU) for Vitamin A whereas Canada uses Retinol Equivalents (RE)
• Daily Value for nutrients such as Vitamin C and Iron
• Different values from nutritional analysis can result for the same formulation
• Ingredient/allergen declarations – Baking powder requires a parenthetical listing of sub-ingredients in the U.S. but not on Canadian food labels
• Not every ingredient allowable in the U.S. is also allowable in Canada and vice versa; food colors can also be an issue
• Net content statement – 4 oz (113g) note no space before the “g” in the U.S., whereas it appears as 113 g with a space in Canada
• Nutrition/health claims – Canada defines “source of” as 5% or more of Daily Value but in the U.S. this is an undefined claim that cannot be used

Take a look at some one-page comparisons of food labels to see the nuances between U.S. and Canadian requirements.
• Allergens side-by-side comparison
• Ingredients side-by-side comparison
• Nutrition Facts side-by-side comparison
• Nutrition/health claims side-by-side comparison

Managing food label issues at the border
Food labels for imported products that must pass through customs are subject to more scrutiny than those that are domestically produced. In addition to customs agents at the border, there are also FDA (for U.S.) or CFIA (for Canada) officials who are reviewing food labels before products are allowed entry into the country.
So after all your nutritional analysis, food labels can still be rejected at the border. What do you do if your shipment is detained? Consider the following approaches:
1. Negotiate a one-time entry of the current product before the required change to your food labels
2. Consider over-stickering food labels to cover problematic areas and satisfy requirements
3. For issues involving ingredients or formulation, nutritional analysis, food labels can be guided by your product development expert to support compliance with federal standards

Food labeler beware! Understanding the nuances between U.S. and Canadian labeling and formulation requirements can be tricky. Don’t let your products be the ones detained at the border.

About the author – Karen C. Duester
President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs.

The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com

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Nutritional analysis, food labels – A quick comparison of U.S. and Canadian food labels

By Karen Duester | Published: May 25, 2012

Nutritional analysis, food labels for the U.S. and Canada are some of the most popular topics from Food Label News, a monthly e-newsletter about what matters in food labels (www.foodlabels.com/newsletter).

As many are aware, it is not possible to have food labels that satisfy requirements in both countries. While both the U.S. and Canada participate in Codex, the international body that provides guidance on food safety and food labels, each country is responsible for its own set of regulations for food labels. Unfortunately for those involved with developing food labels, these regulations are not co-developed.

Preparing nutritional analysis, food labels requires more than ultimately adding French to a U.S. label.

Take a look at a sampling of some of the key differences on nutritional analysis, food labels between the U.S. and Canada. Each country has different requirements. “Nutrition Facts Panels” in the U.S., “Nutrition Facts Tables” in Canada – ah, the differences begin.

• Nutrition Facts side-by-side comparison – The countries require different formatting and have several other key differences such as “Servings Per Container” and “Daily Values” footnote are required on U.S. labels only. While bilingual (English/French) is an obvious Canadian requirement, there are several other country-specific requirements that often result in different values for the same formulation.
• Rounding rules – In Canada, trans fat has tighter reporting requirements than in the U.S., for example.
• Units for reporting nutrients – U.S. uses International Units (IU) for Vitamin A whereas Canada uses Retinol Equivalents (RE), for example.
• Daily Values for nutrients – Differences for example in Vitamin C and Iron
• Nutrition/health claims side-by-side comparison – Canada defines “source of” as 5% or more of Daily Value but in the U.S. this is an undefined claim that cannot be used, for example.
• Ingredients side-by-side comparison – For example, baking powder requires a parenthetical listing of sub-ingredients in the U.S. but not in Canada.
• Allergens side-by-side comparison – U.S. has required “Big 8″ allergen labeling for packaged foods. Canada’s allergen labelling regulations expand beyond U.S. requirements to target not only food allergies, but also celiac disease and sulfite sensitivity.
• Net Contents statement – 4 oz (113g) note no space before the “g” in the U.S., whereas it appears as 113 g with a space in Canada.

For those developing food labels, it’s fair to beware. The differences extend beyond labeling to formulation. For example, not every ingredient allowable in the U.S. is also allowable in Canada and vice versa; food colors can also be an issue.

About the author  – Karen C. Duester
President of Food Consulting Company

Karen Duester founded Food Consulting Company in 1993 to deliver nutrition analysis, food labeling and regulatory support to ensure 100% compliance with FDA regulations. With over 1,500 clients worldwide, Food Consulting Company functions as the virtual food label department for start-up and established food manufacturers, distributors, food importers, brokers, and restaurateurs.

The company’s promise is to deliver accurate, timely service providing everything that’s needed to go from recipe to retail – all with the confidence that it’s done right. Company information and a free email newsletter are available at http://www.foodlabels.com

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First Post

By Karen Duester | Published: March 12, 2012

First Post Test.

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