Volume 17, Number
6 -
June 2017
Happy Summer Solstice from Food Label News.
This month we cover the complexities of flavor and food
label regulations. Whether it's whole ingredients,
natural or artificial flavorings, or combinations of the
three, there are specific rules for flavor naming. Read
on to see which scenario relates to your products. We
also expand on the 2016 Nutrition Facts label changes in
the monthly Reader Q&A with information on rounding
rules.
In this issue you'll find:
|
|
"I find your monthly newsletter,
Food Label News, very
helpful. Thanks for having such
a great resource available."
–
Rob Bradley
Family Fresh Pack
|
|
|
Karen C. Duester, President
|
|
Flavors and FDA Food Labeling Rules
Flavor labeling rules are some of the most
difficult regulations to decipher for food
labelers. What's tricky is when strawberry
pastries contain both strawberries and
strawberry flavoring. Can the pastries be
called "strawberry pastries"? What if the
pastries do not contain actual strawberries
but are flavored with strawberry? Does it
matter if the flavoring is natural or
artificial? What if the package depicts a
dancing strawberry?
|
|
The requirement for listing flavors in the
ingredient statement is relatively
straightforward. There are specific
definitions for "natural flavors" and
"artificial flavors" in
21 CFR 101.22 which dictates the
ingredient name to use. |
The confusing part about flavor labeling for
many is when the flavor is included in the
product name and/or graphics. What matters
is how the "characterizing flavor(s)"
– that
is, the primary recognizable flavor(s) – are
conveyed in the product name and on the
package. When a flavor is included in the
product name or implied through a graphic,
specific regulatory copy must accompany the
flavor name in all locations on the package
and be presented in at least half the type
size of the flavor name. Read on to learn
which regulatory copy is required for each
of the common scenarios.
|
Use of "flavored" –
Strawberry flavored pastry or Strawberry
naturally flavored pastry |
• |
Natural flavor is added; none of the
characterizing ingredient is in the formula
|
• |
Natural flavor is added; some characterizing
ingredient is in the formula, but not enough
to independently characterize the flavor
|
Use of "with other natural flavors" – Strawberry flavored pastry with other
natural flavors
|
• |
Natural flavors derived from multiple
sources are added to enhance the
characterizing flavor (for example:
strawberries, raspberries and blueberries),
and either none or not enough of the
characterizing ingredient is in the formula
|
Use of "artificial flavors" –
Strawberry artificially flavored pastry
|
• |
Artificial flavors are added to simulate or
reinforce the characterizing flavor, with or
without the characterizing ingredient in the
formula
|
• |
Natural flavor not derived from the
characterizing flavor name is added (natural
raspberry flavor added, not strawberry
flavor), and either none or not enough of
the characterizing ingredient is in the
formula
|
Use of "natural and artificial flavors"
– Strawberry naturally and artificially
flavored pastry
|
• |
Though not specifically dictated in the CFR,
when artificial flavors are required in the
name and natural flavor is also in the
formula, it is a common industry practice to
list both in the regulatory copy
|
Use of actual ingredient name; does not
require use of term "flavored" –
Strawberry pastry
|
• |
Characterizing ingredient is enough to
independently provide flavor, even if
natural flavor is added
|
|
Often foods will contain flavors
as sub-ingredients of recipe components.
These may or may not affect characterizing
flavor naming. A chocolate chip with
artificial vanilla flavor used as a
sub-ingredient in a chocolate chip cookie
would not require "artificially flavored" in
the chocolate chip cookie product name.
However, a strawberry pastry that contains a
strawberry artificially flavored dried
cranberry ingredient would need to include
"artificially flavored" in the strawberry
pastry name.
|
|
What's
News
in the Food Label Community
|
|
Reader Q&A
Find answers to our readers' questions or send us your question for an upcoming issue.
Q.
|
What are rounding rules for
actual quantities and % Daily
Values for all mandatory
nutrients declared in the
Nutrition Facts label, per the
new 2016 regulations?
− M.D., India, Food
Manufacturer
|
A.
|
Nutrients that were not changed
in the 2016 Nutrition Facts
label regulations follow
existing rounding rules. Added
Sugars follow the same rounding
convention as Total Sugars, and
FDA has released Draft Guidance
with recommended rounding
increments for Vitamin D,
Calcium, Iron and Potassium.
See a
quick one-pager
on FDA rounding rules.
More Reader Q&As.
|
|
|
|
|
What Matters in Food Labeling
Food Label News, now in its 17th year, is a monthly e-newsletter reaching over 10,000 subscribers around the world. We welcome your colleagues to subscribe for news and insights about food labels: www.foodlabels.com/subscribe
|
|
Your Virtual Food Label Partner
Food Consulting Company, founded in 1993, provides nutrition analysis, food labeling, and regulatory support for more than 1,500 clients worldwide.
Our guarantee: 100% regulatory compliance. Contact us for the help you need now.
You may reprint all or part of this newsletter provided you attribute it to Food Label News and include a link to www.foodlabels.com.
© 2017. Food Consulting Company, Del Mar, CA. All rights reserved.
|
|