Labeling and Consumer Protection

Proprietary Mix Committee

Regarding the Proprietary Mix Committee (PMC) letters and proprietary ingredient mixes, we are still providing the voluntary service of providing such letters for manufacturers of process and blended flavorings, breading/batter mixes, condiments and seasonings, sauces, antioxidant blends, dough conditioners, marinades, pumps, and pickles. The Labeling and Consumer Protection Staff (LCPS) has successfully informed most ingredient manufacturers that they do not need to request such letters. The volume of letters has decreased from about 4000 per year to about 400. However, inspectors will continue to see them for some time to come because there are more than 25,000 out there.

1. We continue to advise meat, poultry, and egg manufacturers that they are responsible for assuring that all ingredients used in formulating products are disclosed in labeling, and that the ingredients are used at levels in accordance with the regulations and consistent with regulations on common or usual names of ingredients. Therefore, processors are responsible for obtaining from their ingredient mix suppliers accurate information to declare on their products' ingredients statements.
    
2. Under the generic labeling approval scenario, the complete disclosure of ingredients and the percentages of all ingredients in product formulations must be part of the labeling records that the meat/poultry establishment maintains. These records must be made available to the program official at any time.
    
3. There are still general tasks for inspectors that are associated with assuring that ingredients used in formulating meat and poultry products are acceptable. Inspectors can always take action on (1) labeling of bulk containers of ingredients that do not disclose all ingredients in the mix, (2) finished products they suspect have ingredients that are not disclosed on labeling, and (3) ingredients in the plant that are not permitted in meat/poultry products. We suggest that inspectors who question the identity of an ingredient mix or the permitted uses of ingredients contact the TSC. The TSC may have to contact the LCPS for policy guidance.
    
4. While the Agency has the current prior labeling approval system, the Agency cannot deny providing a vehicle for the ingredient industry to use as an alternative to forcing them to disclose their "secret" ingredients to meat and poultry processors. Therefore, historically, we have provided the voluntary service of the Proprietary Mix Committee (PMC). The Agency has allowed ingredient manufacturers to send the formulations of ingredient mixes and the detailed description of how they are made to the Agency where the information is evaluated. The LCPS uses the formulation (percentages) and processing information in the PMC submission to advise the ingredient manufacturer on the acceptable labeling of the ingredients and their order of predominance in meat/poultry products. Written advisory letters are written in response in order to assist the meat/poultry processor at the time of label approval.

If inspectors question the accuracy of a PMC letter, they should contact Tawana Duncan in the LCPS.

5. As always, if inspectors see proprietary mixes for which the processor does not disclose ingredients on a label transmittal or meat/poultry label, the inspectors should ask plant management for the explicit breakdown of the ingredients in the mix in order to be assured that the mix is acceptable for use in meat/poultry products and that the meat/poultry are truthfully labeled and not adulterated. The inspector should consult with the TSC and LCPS. If the processor does not provide the information or a PMC letter is not provided, then the product would be misbranded and the inspector can withhold production (i.e., use of the label) until the suitability of the ingredient mix and the accuracy of the label is determined.

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