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Food Nutrition Labels Made Simple: A Guide to Creating Compliant Nutrition Labels

There are a few major items you must consider when creating food nutrition labels and designing nutrition labels for food packaging packaging. These items may vary depending on what type of product you are labeling and they are:

  • Required elements – What types of information does the food type require you to display?
  • Nutritional labeling – What is the nutritional value of your food product?
  • Label claims – Are you using valid claims about your products? i.e. Light, Fat Free.
  • UPC claims – Who manufactures and as a result is responsible for the safety of your product?

When is a Food Nutrition Label Required?

Food Nutrition Labels are not required of all food producers. If your business or products qualify for any of the points below, you are required to list the nutritional value of your products on your labels.

  • Selling >$50,000 food/year OR
  • Making nutritional or health claims on the label
  • Is a Fortified Food
  • Is Baby Food
  • Is a Buyer requirement
  • Is a Consumer Preference

 

Food Nutrition Label Facts

If you have determined that your business or product requires nutritional labels, the next step is identifying what the nutritional content of your food product is. There are several companies that have the ability to analyze your product for nutritional content. They will identify items like:

  • Serving Size
  • Calories,
  • Key Nutrients

 

Food Nutrition Labels  and Regulations

Several agencies are in place that will regulate the validity of your label statement and/or nutrition claims.

Product Type Responsibility
Meat & Poultry* VAAFM – Meat Inspection
Dairy products* VAAFM – Dairy
Alcohol* (>0.5% in products not cooked) VT Dept. of Liquor Control
All other food products VAAFM-Consumer Protection

*Agencies responsible for regulation food packing will allow producers to submit their labels prior to printing, to ensure the standards of compliance are met. 

 

General Food Nutrition Label Requirements

Though food product categories may differ, certain items are required among all categories. They are:

1. Identity of product – This is the common name of the food, if one applies. i.e. Ice cream, pudding, salsa, etc. The name of the food must appear on the front of the label, in a bold font. The brand name should be smaller. A good rule of thumb is to print the brand name at half the font of the identity of the product.

  • Name cannot be misleading or deceptive
  • Describe form of food (sliced or chunks)

2. Quantity – These items must be placed on the lower 30% of your packaging.

  • Accurate description of weight, volume and number of products in package
  • Solids: weight; Liquids: volume
  • Combination : weight or volume – both in metric and in customary

Font Size is Determined by area of PDP

  • Rectangle PDP: height multiplied by width:  8” x 4” = 32”. Label must occupy 30%
  • Cylinder PDP: Diameter multiplied by height times two (to account for dual side visibility).

Example: 4 Large Ounces is non-qualifying, it should be 4 ounces.

Do NOT include packaging weight, only food weight.

 

Filled container weight 18 oz
Empty container weight 2 oz
Wrapper weight 1 oz
Net weight 15 oz

You may include water or liquid in net weight (of liquid normally consumed)

Fruit weight 9 oz
Water weight 4 oz
Sugar weight 1 oz
Net weight 14 oz

 

Determining Your Font Size

Diameter X Height = Total square inches of PDP,  40% of that total space must be labeled in a font that is clear and easy to read. Qualifying statements are not allowed.

Area of PDP Minimum Type Size
< 5 in² (32cm²) 1/16 inch (1.6mm)
5-25 in² 1/8 inch
25-100 in² 3/16 inch
100-400 in² ¼ inch
>400 in² ½ inch

3. Declaration of Responsibility:

  • Name and address of manufacturer, packer or distributor taking responsibility. Unless name and manufacturer are the same, you will  need a qualifying phrase “manufactured for” or “Distributed by”
  • Where: on the front panel or with ingredients on info panel (side panel)
  • Address = city, state, zip. Street address can be omitted if address available in phone book.
  • Font: must be conspicuous
  • Exemption: Not required if product sold on same premises where it was packed
  • Note: Identity, quantity, and responsibility may be hand-written if legible and correct size.

4. Listing Ingredients:

  • Needed if more than one ingredient
  • List of predominant ingredient (by weight) first , least predominant last, even ingredients in trace quantities
  • Ingredients must be listed on the same label panel as responsibility
  • Font size: ≥1/16 in (lower case “o”)
  • If product contains a processed food (enriched flour), also list ingredients of that food
  • List common name ie “sugar”, not sucrose

Labeling Allergens

Allergens must be listed either adjacent to (directly above or below) ingredient list or included inLabeling Food Allergens ingredient list. No exceptions.

See: Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA).

8 Major Allergens:

  • Peanuts
  • Tree Nuts
  • Milk (Dairy)
  • Wheat
  • Soy
  • Fish
  • Crustacean
  • Eggs

Allergen Advisories

  • “may contain [allergen]” or “processed in a facility that also processes [allergen]”
  • FALCPA does NOT address “advisory labeling”
  • Advisory labeling should NOT be a substitute for good allergen GMP’s
  • Statements must be truthful and not misleading
  • Foods may be listed as Allergen-Free by Allergen Free International after testign is complete and has been documented.

Meat Labeling

Meat labeling has secondary requirements above the standards of compliance found in most other food types. Those additional items are:

  • Official inspector legend
  • Handling statement (i.e. keep refrigerated)
  • Safe handling instructions
  • Nutrition facts in meat – if:-Large processor (≥100,000 lbs/yr)-Selling major cuts to consumers? Producer must have their label approved by VAAFM prior to distribution.

 

Content Nutrition Label Claims

Only FDA approved label claims may be used on food labels and packaging. Meat products must have nutritional claims substantiated and the costs associated are the responsibility of the producer. Documentation is required to substantiate any all label claims.

Ex: “Low fat” label claims must contain less than 100 calories and have the documentation of testing and proof to support the claim.

Once your label claim has been substantiated, the claim must be printed in a font size <2x as product names

 

Health Food Label Claims:

Qualified health claims have very specific requirements.

  • A health claim is any statement, image, etc. trying to relate food to disease or health-related condition. Ex: Calcium may reduce the risk of osteoporosis. All label claims must be true and not misleading.

 

Gluten Free Label Claims:

  • Gluten is certain proteins that occur naturally in wheat, rye, barley and hybrids. Certain individuals have in intolerance to gluten, therefore, products that do not contain  wheat, rye, barley, crossbred or the derivatives  may be labeled to be more easily identified by consumers. Learn more about gluten free label claims on the FDA webste.

There are several companies that perform gluten-free testing and offer certification:

  •      Celiac Sprue Association
  •      Gluten Intolerance Group
  •      National Foundation for Celiac Awareness

 

Non-Dairy,Dairy Free and Lactose-Free Label Claims:

Dairy-Free

  • No FDA regulations
  • Items have no diary products in them what-so-ever

 

Non-Dairy

  • FDA regulated
  • Regulation allows milk proteins (casein, whey)

 

Lactose-Free

  • Could contain whey, casein (allergens)

 

Other Food Label Claims:

 

Vegetarian Label Claims – Food produced with no meat or animal byproducts.

  • No federal regulation or terms
  • Some companies set their own standards
  • Many third party certificates

 

Fair Trade Label Claims:

  • Must meet Fair trade standards
  • International and US standards
  • Sustainable, Local or Artisan Label Statements
  • No federal definitions
  • Must be truthful and not misleading

 

Fresh or Natural Label Claims: Defined for Meat

  • The word “natural” with an asterik after: *minimally processed, contains no artificial    ingredients”
  • “fresh” poultry” = never <26°F

 

Production Label Claims 

  • “Certified Organic”: NOFA-VT
  • “Grass fed”, “free range”, “raised without antibiotics” requires USDA or VAAFM approval
  • “Humanely raised”: independent auditors are available to substantiate these claims
  • Producers CANNOT claim “antibiotic free” or “hormone free”