Do you remember this news story from October? A granola manufacturer wanted to highlight the care that went into making its products, so the company added “love” to the ingredient lists on their product labels. But FDA objected to this, since love is not the common and usual name of an ingredient in the product.
The regulations for ingredient labeling state that all ingredients must be declared by their common and usual name, which is sometimes set by regulation or by a Generally Recognized as Safe (GRAS) notification. Brand names or extra descriptions (e.g., “super creamy milk”) are not allowed in the ingredient list. Additional statements about ingredients could be made elsewhere on the label, as long as they are truthful and not misleading.
This is an excellent reminder to double check the claims and label statements on your products. As you update labels to comply with the new Nutrition Facts format, other updates may also be in order. However, make sure that any changes meet the requirements for labeling requirements and that you aren’t inadvertently making an implied nutrient content claim or health claim. For example, “100 calories per serving” is a truthful statement, but “only 100 calories per serving” implies a low calorie claim, and 100 calories per serving does not meet the definition for low calorie.
For more information on labeling, IDFA members can contact me at firstname.lastname@example.org or Cary Frye, IDFA senior vice president of regulatory affairs, at email@example.com.
Stay tuned for more information on the updated labeling manuals, which will be out soon.