USDA. Product & Ingredient Naming
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1 USDA Product & Ingredient Naming
2 USDA Product Naming and Ingredient Naming-Contents 1. Introduction 2. Statement Identity / Product Name 3. Ingredients Labeling 4. Conclusion 2 Inc. All rights reserved.
3 Labeling vs. Label Labeling : on package, flyer, web site, etc All labels and other written, printed or graphic matter: 1. Upon any article or any its containers or wrappers, or 2. Accompanying such article Label : on package A display written, printed, or graphic matter upon the immediate container any article 3 Inc. All rights reserved. 9 CFR 317.2
4 Product Name (Statement Identity)
5 Statement Identity: General Guidelines Must appear on Principal Display Panel Parallel to the base Legible In English Product Name 5 Inc. All rights reserved.
6 Statement Identity: FDA & USDA Differences must be legible & reasonably sized 6 very specific requirements for: Sizing Wording Placement Inc. All rights reserved.
7 Product Form Must be described if available in different forms 7 Sliced, chunked, ground, whole, halved, etc Inc. All rights reserved.
8 Product Name Three Types Product Name: 1. Fanciful Name e.g. Corn Dog 2. Descriptive Name e.g. Batter Wrapped Franks on a Stick 3. Standard Name e.g. Beef Salami 8-9 CFR 317.2(c) & 9 CFR Inc. All rights reserved.
9 Product Name Fanciful name is not enough: Must be accompanied by either a descriptive name or standard name Descriptive or Standard name IS enough. 9 9 CFR 317.2(e) & 9 CFR (a) Inc. All rights reserved.
10 Product Name-Standard Identity Rules Thumb: Standards exist for many finished products 10 Inc. All rights reserved.
11 Product Name-Standard Identity Conforms to ingredients/processing rules: Ex: SALAMI, BEEF: cooked, smoked sausage, usually mildly flavored, in a large casing, containing coarsely ground beef. Cereals and extenders are permitted. May contain fat. Product does not have to be labeled cooked. A salami with a moisture protein ratio no more than 1.9 to 1. Ex: TAQUITOS: Mexican dish requiring at least 15 percent meat. Cooked meat product is cut into strips or shredded and placed in center tortilla. The tortilla is then rolled around the filling CFR 319, 381 & Standards & Labeling Policy Book Inc. All rights reserved.
12 Product Name Sometimes Names must have additional Qualifying statements such as: Caramel Color Added With Natural Juices Smoke Flavoring Added Tenderized with Papain These are considered part the Product Name and should be next to it at all times. Some qualifiers have size requirements 12 Inc. All rights reserved.
13 Product Name Solution Rule Ingredient (Containing) Statement Requirements: On Principal Display Panel Include all solution ingredients Percent as a number Statement 1/3 the size largest letter in product name (1/1/2018) Contiguous & same size, font, color, and single color 13 e.g. Contains up to 8% solution chicken broth, salt and sugar marinated basted for flavor flavored with enhanced Inc. All rights reserved.
14 Product Name Qualifiers Type Cured Pork Products Uncured Products Packets Additional Components Containing Statements* (Old rule) Graphics Requirements 1/3 size largest letter in PN, same color, style, font & color background Part PN & before it, same size & style as PN, adjacent additional text, ½ size PN no nitrite & not preserved State presence packet, 1/3 size PN & contiguous to PN containing up to % a solution ( water, salt and spices), contiguous to PN, 1/4 size PN, ingredients at least 1/8 size PN 14 Inc. All rights reserved.
15 Product Name Qualifiers Continued No size requirement - but must be contiguous to the Product Name, prominent, & conspicuous Type Qualifier Acceptable statements 15 Artificial Smoke Flavoring Artificial Coloring Antioxidants Enzymes Preservatives in Pizza Crust Ice Glazed / Water Misted Artificial Smoke Flavoring Added Smoke Flavoring Added Artificially Colored Artificial Coloring Added Colored with (for natural colors, e.g. Annatto) State the antioxidants used and purpose, e.g. BHA, BHT, Propyl Gallate Added to Help Protect Flavor Tenderized with [Enzyme] [Preservative] added to retard spoilage crust Product protected with ice glaze - 9 CFR 317.2(j) & 9 CFR (b) Inc. All rights reserved.
16 Product Name Graphics Requirements Fanciful Descriptive Qualifiers w/ Size Qualifiers w/o Size 1/3 Grandma s Stew Beef and Vegetables in Sauce Seasoning Packet Included Artificial Coloring Added 1/3 Contiguous, prominent, conspicuous 1/3 Contiguous, prominent, conspicuous 16 Inc. All rights reserved.
17 Product Name Poultry Species Many products require the species as part the product name. PDP IP The species is also generally considered material within a descriptive name. 17 Inc. All rights reserved.
18 Product Name Poultry Naming Proportion light or dark meat must be declared as part the product name* Label terminology Percent light meat Percent dark meat Light or white meat Dark meat Light and dark meat Dark and light meat Mostly white meat 66 or more 34 or less Mostly dark meat 34 or less 66 or more Natural proportions * Unless it is present in natural proportions, less than 10% formula or identity is obscured (ground) Inc. All rights reserved.
19 White Meat Chicken vs. White Chicken Meat White meat chicken includes skin in natural proportions. "White chicken meat" does not include skin; in this case the skin would need to be declared separately in the IS. Please note that the product name should reflect the type meat (light/white or dark) when the type meat is declared in the ingredients statement. 19 askfsis via 03/03/ :40 AM Inc. All rights reserved.
20 Product Name Poultry Naming Whole poultry must state age & species 100% White Meat Natural Proportions 20 Inc. All rights reserved.
21 Ingredient Statements
22 Ingredients Statement A list the product ingredients in descending order predominance Predominant by weight By specific ingredient Principal Display Panel Information Panel 22 Inc. All rights reserved.
23 Ingredient Statement For products with 2 or more ingredients: Must state the word Ingredients:. ** Ingredients must be stated in order predominance **Exceptions: 1. Cured products = Cured with 2. Containing statements = *Solution ingredients 23 9 CFR & 9 CFR Inc. All rights reserved.
24 Ingredient Statement No minimum size requirements, must be legible 24 Inc. All rights reserved.
25 Ingredients: Use Statement Identity Ground Wheat Wheat Flour Or Common & Usual Name Sugar Sucrose 25 Inc. All rights reserved.
26 Ingredients: Use Specific Names Vegetables (tomato, carrot, spinach), Water, Salt, Pepper Water, Tomato, Carrot, Spinach, Salt, Pepper Avoid abstract grouping ingredients to affect the apparent order predominance 26 Inc. All rights reserved.
27 Ingredients Statement: Complex Ingredients A complex ingredient is made up more than one ingredient. 27 The elements a complex ingredient must be sublisted, in parentheses, after its name (including flavors with sublistings). - 9 CFR & 9 CFR Inc. All rights reserved.
28 Ingredients at 2% or less To avoid packaging reprints or to conceal formulas, ingredients at 2% or less total formula may be listed in any order, provided: They are preceded by the statement Contains 2% or less or Less than 2% (May use 1.5% or 1% or 0.5% if all ingredients listed meet that maximum level.) 28 9 CFR & 9 CFR Inc. All rights reserved.
29 Ingredient Statement Required UNLESS: Product Name provides a complete identification all ingredients in the food e.g., Chicken Breasts with Rosemary Extract 29 Inc. All rights reserved.
30 Ingredient Categories Fat and Oil Blends Spices Flavors 30 Inc. All rights reserved.
31 Fat & Oil Blends May use category with and/or designation Must state source: animal, vegetable, marine Must list all potential oils included Not allowed if fat/oil is the primary ingredient For use when predicting oil source is difficult Example: Vegetable Oils (Corn oil, safflower oil, and/or canola oil) 31 Inc. All rights reserved.
32 Flavoring, Spice & Seasoning Can list certain ingredients under specific grouping types: Flavorings: All spices, extractives or oleoresins spices and certain fruit or vegetable extracts Spices: Ingredients commonly used as spices, NOT garlic and onion; herbs are spices Seasonings: Must be listed or sublisted by name; seasonings can contain specific ingredients, including flavorings and spices with other ingredients, e.g. salt. 32 Inc. All rights reserved. 32
33 Spices Declared by the common and usual name or collectively using spices : Apples, water, sugar, ginger, cinnamon, nutmeg Apples, water, sugar, spices Apples, water, sugar, spices, cinnamon 33 Inc. All rights reserved.
34 Spices and Flavorings that Impart Color Spices and flavorings that impart color to a product cannot be listed simply as flavorings or spices in the IS. Instead: Use the common name (paprika, turmeric) List as spices and colorings List as flavorings and colorings 34 Inc. All rights reserved. 34
35 Conclusion
36 Speaker Bio Justin Crews: Regulatory and Quality Roles with Windsor Food-QA Home Market Foods-QA & REG Pinnacle Foods- QA & REG Wellshire Farms- QA and COMPLIANCE 36 Inc. All rights reserved. 36
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