While flavor declarations are a cinch, the FDA labeling requirements for the flavor designation on the principal panel display are complex and confusing. Even conventional foods and dietary supplements can be difficult to label when it comes to the FDA’s required Statement of Identity—get things wrong and you could find yourself on the FDA’s bad side.
Getting your product in front of consumers means getting your Statement of Identity right, including the appropriate name and the right placement and format, says food labeling expert Gisela Leon in her webinar for ProfEdOnDemand, “Statement of Identify, Flavor Designation and Declaration.” Leon also implores label reviewers and creators to be aware of the definitions of natural and artificial flavors and multiple scenarios of flavor designation on the principal display panel.
FDA Rules: Principal Panel Display Measurements Detailed In Guidance Document
The bulk of the FDA’s food label declaration rules are spelled out in “A Food Labeling Guide: Guidance for the Industry,” a 122-page document last updated in 2013 and translated into Spanish, Arabic, Hindi, Chinese, and Japanese. Instructions for the principal display panel are described in detail, including the ratio between minimum type size (in inches and millimeters) and the area of the panel. The same goes for the Statement of Identity.
The background for FDA labeling requirements and a run-down of what resources are available can be found on a separate FDA guidance page.
Agency Released Three Guidance Updates At End Of 2018
The agency issued three guidance updates at the end of last year.
Draft guidance in November spelled out “reasonable” serving sizes, reference amounts, and dual-column labeling. A guidance report, also from November, supplied information in a question-and-answer format for nutrition and supplement fact label compliance dates, added sugars, and vitamin and mineral declarations.
Then, in December, the FDA announced that Jan. 1, 2022, will be the uniform compliance date for all final food labeling regulations issued in 2019 and 2020. The December announcement also finalized draft rules published back in 2016 which corrected mistakes in some label illustrations, restored inadvertent deletions, and corrected cross references.
The November announcement about sugar is important for some food makers, said the American Dental Association in a press release.
“Beginning in 2014, the ADA successfully lobbied to have ‘added sugars’ declared separately from ‘sugars’ as a whole on Nutrition Facts labels, and also to include ‘naturally occurring sugars that are isolated from a whole food and concentrated so that sugar is the primary component (e.g., fruit juice concentrates)’ in the definition of ‘added sugars,’” the organization stated.
Those rules go into effect on Jan. 1, 2020 for manufacturers with $10 million or more in annual food sales and 2021 for those with less than $10 million.
Turn Rules Into An Asset, Expert Urges
While the rules can’t be skirted, Carol Best, a vice-president at marketing firm SGK, told Packaging Digest that they can be used to your advantage.
“We see the Nutrition Label update as an opportunity to listen to consumers and give them even more of what they want—going beyond simple compliance to deliver a real brand advantage,” she said. “The entire industry must make labeling changes. The big winners will be brands that see this as a strategic opportunity, not just an imposed burden.”
While the opportunity is there, Leon stresses in her webinar that there are a host of facts and details to get right. Goof and your product may be held back – but get it right and you are one step closer to sales.
