The Ins and Outs of Food Labeling (Part

One)This module is adapted from: the FDA Food Labeling Guide,

www.cfsan.fda.gov/~dms/flg-toc.html

Module designed by Tera Sandvik, LRD, Program Coordinator; Julie Garden-Robinson, PhD, LRD, Food and Nutrition Specialist; and Tami Totland, RD, Program Assistant

2007

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Overview This module provides basic

information about food labeling. When you have completed this module, you should have a general knowledge of the basic rules and regulations associated with food labeling.

Presurvey Before we begin, let’s take a presurvey to

see how much you already know. Click here to begin.

History of Food Labels In November 1990, the Nutrition Labeling

and Education Act (NLEA) became federal law.

NLEA: Requires most foods to bear nutrition labeling Assists the Food and Drug Administration (FDA)

in assuring all foods sold in the U.S. are safe, wholesome and correctly labeled

Regulates the labeling of nutrient content and health claims

History Cont. In 1993, the FDA and Food Safety and

Inspection Service (FSIS) published detailed regulations defining how to comply with NLEA labeling requirements.

NOTE: Changes and amendments are being made to

these regulations continuously. The food industry is responsible for remaining

current with the legal requirements for food labeling.

History Cont. The Code of Federal Regulations (CFR)

contains all final regulations issued by the FDA and USDA by numbered “Titles.” Title 9 contains USDA regulations on animals

and animal products. Title 21 covers FDA regulations on food and

drugs. The CFR can be accessed via the Internet

at: http://www.access.gpo.gov/nara/cfr/waisidx_09/21cfr101_09.html

The function(s) of NLEA include:A. Requiring most foods to bear nutrition labels.B. Assisting the FDA in assuring foods are safe,

wholesome and correctly labeled prior to consumption.

C. Regulating nutrient content and health claims on food products.

D. All of the above

If you chose “D,” you were correct. NLEA provides all of the services listed above.

Click to see the answer.

Where can the latest FDA and USDA regulations be found?A. The Department of EducationB. The Department of CommerceC. The Code of Federal RegulationsD. None of the above

If you chose “C,” you were correct.

Click to see the answer.

Does your business qualify for an exemption?

Exemptions Certain small businesses and businesses

meeting other specific criteria are excused from nutrition labeling.

These exemptions apply only if no nutrition claim or information is on the product packaging or in advertising.

Foods Under FDA Regulations The FDA handles all domestic and

imported food sold in interstate commerce, including shell eggs, but excluding meat and poultry.

The FDA also oversees bottled water and wine beverages with less than 7 percent alcohol.

FDA Small-business Exemptions If you qualify for the FDA small-business

exemption and plan to utilize the small-business exemption, your business must file an annual notice with the FDA.

If your product or business surpasses the following criteria, the exemption will expire within 18 months from that date.

If you answer “yes” to one of the following you qualify for the FDA small-business exemption.

In my most recent two-year average, my annual gross sales to consumers equals less than $500,000 or my annual gross sales of only food to consumers equals less than $50,000.

My business employs fewer than 100 employees (based on the average FTEs) and has product* sales of less than 100,000 units** for each product.

* A “product” is defined as a food with the same brand name and statement of identity.

** A “unit” is defined as the package or form in which the product is offered for sale.

FDA Small-business Exemption Cont.

Other FDA Exemptions If you answer “TRUE” to any of the following

statements for your business, you may be excused from nutrition labeling.

I manufacture a food product that contains insignificant amounts of all mandatory nutrients (e.g. plain coffee or tea, some spices).

My business manufactures restaurant and food service foods sold for immediate consumption.

The food my business produces is ready to eat, prepared largely on-site and is not sold outside of that location (e.g. deli or bakery foods).

My business manufactures foods that will be further processed, packed or labeled at another location.

Julie’sCoffee

FDA Exemptions Cont. My food product is packaged with less than 12

spare inches of labeling area and no nutrition claim is made on the product. On the packaging, I have provided an address or telephone number where consumers can obtain nutrition information.

My business manufactures properly labeled multiunit containers, which consist of unlabeled individual units. The individual units indicate they are not labeled for retail sale.

My business sells foods from bulk containers. The bulk containers are properly labeled.

FDA Exemptions Cont. My business manufactures or sells single-

ingredient fish or game meats. I produce infant foods, formula or medical

foods (subject to separate regulations). The food(s) my business sells are among

the 20 most commonly consumed raw fruits, vegetables and fish (subject to voluntary regulations).

USDA Regulations The USDA oversees all domestic and

imported meat and poultry and related products (e.g. meat or poultry-containing stews, pizzas and frozen foods). Also under USDA control are processed egg products.

If you answer yes to the following statements, you are excused from labeling requirements.

USDA Exemptions The food(s) my business produces are raw,

single-ingredient meat and poultry products (e.g. ground beef, chicken breasts), which are subject to voluntary regulations.

My business employs fewer than 500 employees and has sales of less than 100,000 pounds annually, based on the most recent two-year average.

USDA Exemptions Cont. My food product is packaged with less than 12

spare inches of labeling area and no nutrition claim is made on the product. On the packaging, I have provided an address or

telephone number where consumers can obtain nutrition information.

My business prepares, serves or sells food products that are: ready to eat and are packaged or portioned at retail multiingredient products processed at a retail store restaurant or food service foods

USDA Exemptions Cont. My business produces a product that

weighs less than ½ ounce net weight when packaged.

My business manufactures a food product that is not for sale to consumers since further processing or export is intended.

If you voluntarily provide a nutrition label or health claim, the exemptions listed above no longer will apply and you will need to meet all labelingrequirements.

A business qualifies for a small-businessnutrition labeling exemption from FDA when:

A. Annual gross sales to consumers is less than $750,000

B. The business employs fewer than 100 workers

C. Product sales equal less than 100,000 units per product

D. B and C

If you chose “D,” you are correct.

Click to see the answer.

What must be provided on the label of a food product with less than 12 square inches of labeling area?A. AddressB. Fax numberC. Web site addressD. No information is requiredE. All are required

If you chose “A,” you were correct.

Click to see the answer.

True or False: A business that meets the criteria for an FDA or USDA exemption, but voluntarily decides to print a nutrition claim of the product, still is eligible to claim the exemption.

The correct answer is “False.”

Click to see the answer.

General Labeling RequirementsFive mandatory components must be on a

food label: Product Identity Net Weight Nutrition Facts (unless exempted) Ingredient Statement Place of BusinessThis information may be located on the

Principle Display Panel (PDP) or Information Panel.

The above information must be printed in English.

Principle Display Panel (PDP) The PDP is the surface area you are able to

see while walking down the grocery store aisle.

The height times the width of the PDP determines the type size requirement of the food label. On cylindrical containers, the surface area of

the PDP can be calculated by multiplying 40 percent of the height by the circumference.

The PDP must include two pieces of information: Statement of identity, or name of food Net quantity statement, or amount of product

PDP Display

How can consumers identify the PDP surface of a food package?

A. The PDP surface is adjacent to the front of the package.

B. The PDP surface is the portion of the package most likely to be seen at the point of purchase.

C. The PDP surface may be located at the bottom or top of a food package.

D. None of the above.

If you chose “B,” you were correct.

Click to see the answer.

What two pieces of information mustthe PDP include?

A. Product identity and Nutrition FactsB. Net weight and ingredient statementC. Nutrition Facts and place of businessD. Product identity and net weight

If you chose “D.” you were correct.

Click to see the answer.

Statement of Identity The statement of identity is the common

or usual name of the product contained in the package (e.g. “soup” or “cereal”).

If no common name is given, then a descriptive name may be used in place (e.g. vanilla wafers).

The product identity is required in the middle portion of the PDP’s front label. It should be dominant and stand out from all

other print and pictures on the package.

Statement of Identity Example

What would the statement of identity be on a can of Superstar’s chicken noodle soup?

A. SoupB. Superstar’sC. Chicken noodleD. Both A and B

If you chose “A,” you were correct.

Click to see the answer.

Net Quantity Statement This statement provides the amount of

food in the container or package. Located in the lower 30 percent of the PDP Often at the lower right corner of the front label Only the quantity of food in the package is

stated in the net quantity statement The weight of the container, wrapping and packing

material may not be included.

The net weight or volume must be listed in both the U.S. scale and metric scale.

Scales U.S. Scale

Ounces Pounds Fluid ounces

Metric Scale Grams Kilograms Milliliters Liters

For example, “NET WT 6 oz. (170g)” would be an appropriate net quantity statement. The required type size will vary by the product’s surface area, with a minimum height of 1/16 inch required.

Net Quantity Statement Example

Which of these is a correct version of a net quantity statement?

A. NET WT 1 lb 8 oz (680g)B. 500 ml (1 pt 0.9 fl oz)C. NET WT 2 Large oz (5g)D. 1 gallon (3.79L)

If you chose “A,” you were correct.

Click to see the answer.

Information Panel The information panel is the surface area

normally to the right of the PDP. This would be the label on the right side of

the box. The information label on a jar would be

directly to the right of the PDP. On the information panel, we find:

Nutrition Facts Ingredient statement Place of business

Information Panel

Post-survey Let’s see what you’ve learned. Click here to begin the post-survey.