|
|
10 Most Common Mistakes And How to Avoid Them |
Access PDF Version
|
10 Most Common Mistakes |
And How to Avoid Them |
-
Either the entire label
is illegible or portions of the
label are illegible.
|
If the label or any
portion of the label is illegible,
it will be returned without being
evaluated. The label application and
corresponding label needs to be
clear and legible in order to
facilitate a proper evaluation by
the Labeling and Program Delivery
Technical Team. Please ensure all
copies of the application form and
label have print large enough to
read and that there is proper
contrast between the printing and
background. Submissions sent in via
fax machine are particularly
problematic. Please ensure when
faxing labels that application and
label will be transmitted so all
portion of the label can be read.
Frequently Asked Q&A's Label
Approval Process |
-
The label is incomplete in that
not all required labeling
features are provided.
|
Refer to the following document for
a list of all required labeling
features. Some features may not be
necessary; e.g., catch weight items
do not require a net weight
statement appear on the label before
leaving the federal establishment.
Checklist for Mandatory Features on
a Label |
-
The label application form is
incomplete:
|
FSIS Form 7234-1 |
-
HACCP category is missing
|
Be
sure to complete block #5b on of the
HACCP categories listed in
9 CFR 417.2(b)(1) e.g.,
heat-treated, not fully cooked, not
shelf stable. |
-
Available labeling space or
PDP space is missing
|
Include the square inches of the
principal display panel for block 7a
which determines the size of the net
weight statement on products sold at
retail. The PDP is the entire side
of the package (not just the label)
to which the label is affixed. Refer
to
9 CFR 317.2(d) and (h) and
381.116 (b) and
381.121. Complete block 7b with
the square inches of the total
available labeling space for the
entire package. This is needed to
determine which nutrition facts
format should be used on the label
if the label bears a nutrition facts
panel. Refer to
9 CFR 317.309(d) and
381.409 (d).
|
-
The product formula is not
presented in a manner to
verify all requirements,
e.g., order of predominance,
restricted ingredient levels
|
Block #8 of the label application
form should agree with the
ingredients statement. Additionally,
the percentage or amount of an
ingredient included in a seasoning
blend should indicate the percentage
or weight in that seasoning or the
exact amount (e.g., sodium nitrite
in a cure mix or sodium phosphate in
a marinade) All ingredients need to
be listed in their proper order of
predominance – Refer to
9 CFR 317.2(f)(1) and
381.118(a)(1). |
-
The formulation, processing
procedure, or supporting
documentation do not agree with
or validate information and/or
claims on the label, e.g.,
"lemon, thyme, pepper" claim on
label but the formulation does
not indicate that the spices
contain thyme and pepper.
|
Ensure that any information on the
application form agrees with
information on the label. In the
example, on a label that states the
product contains lemon, thyme and
pepper but if the application only
lists spices in the application
there is no way to validate that the
label claim about the spices is
true. To avoid this problem, list
the spices on the application form.
The spices do not need to appear in
the ingredients statement just
necessary to validate the label
claim. Refer to 9 CFR 317.2(f) and
381.118(f).
A Guide to Federal Food Labeling
Requirements for Meat and Poultry
Products |
-
Product standards are not met.
|
Please refer to the regulatory
standards in both the
9 CFR 319 and
381 subpart P and the
Food Standards and Labeling Policy
Book
|
-
Product name is incorrect:
|
-
"BBQ" on the label of a
sauce with beef product,
yet, standard 9 CFR 319.80
or 319.312 is not met
|
If the product does not meet the
standard, in certain cases the
product name may be revised to
include the term “flavored” or
“seasoned”. Refer to the
Food
Standards and Labeling Policy Book
for other examples. |
-
Two product names that
conflict, e.g. Chili and
Chili with
Beans
|
A
product names should be consistent
on the label to ensure the name will
not be misleading to the end user.
Food
Standards and Labeling Policy Book |
-
Product name word size is
incorrect
|
Certain products have specific name
sizing requirements; e.g., cured pork
products in
9 CFR 319.104 and turkey ham in
381.170. Generally, the smallest
letter in the product name needs to be
at least 1/3 the size of the largest
letter in the product name. Refer to
Policy Memo 087A for additional
guidance.
Policy Memorandums
|
-
Ingredients statement problems:
|
A Guide to Federal Food Labeling
Requirements for Meat and Poultry
Products |
-
Single ingredients are not
listed by common name, e.g.,
oil declared instead of
vegetable oil, soy declared
instead of soy flour, MSG
declared instead of
monosodium glutamate.
|
All ingredients need to be listed by
their common or usual name not by a
trade name or an abbreviation. Refer
to
9 CFR 317.2(f) and
381.118. |
-
Component ingredients are
not listed by common name,
e.g., cheese declared
instead of imitation cheese,
ham declared instead of ham
water added, beef declared
instead of seasoned beef and
binder product.
|
Ensure that all purchased
ingredients are declared as they are
listed on the purchased product
name. On rare occasions, purchased
products labels are incorrect so it
is helpful if a purchased product
label or an ingredient specification
sheet to verify the ingredient
declaration is correct. Refer to
9
CFR 317.2(f) and
381.118. |
-
Order of predominance in the
ingredients statement is
incorrect.
|
All ingredients need to be listed in
their proper order of predominance –
Refer to 9 CFR 317.2(f)(1) and
381.118(a)(1). |
-
There are ingredients
declared in the ingredients
statement that are not in
the formulation and
vice-versa.
|
The
product formula should agree with
the ingredients statement and the
ingredients statement should agree
with the product formula. |
-
Multi-ingredient components
are missing their sub
listings.
|
Refer to 9 CFR 317.2(f)(1) and
381.118(a)(1). |
-
Nutrition facts problems:
|
Nutrition Labeling Information |
-
The servings per container
are incorrect.
|
Refer to
9 CFR 317.309(b) and
381.409(b) |
-
The serving size is
incorrect.
|
Refer to
9 CFR 317.309(b) and
381.409(b) |
-
The wrong format is used.
|
Refer to
9 CFR 317.309(b) and
381.409(b) |
-
Improper rounding of the
values.
|
Refer
to
9 CFR 317.309(b) and
381.409(b)
The
rounding rules for each nutrient
(vitamin and minerals are listed
collectively) are listed
individually in each nutrient
citation. |
-
Improper reference amounts
are used.
|
Refer to
9 CFR 317.312 and
381.412. Be sure to make sure
the product category is used to
determine the proper reference
amount. Whether the product is ready
to serve or ready to cook is also
important in determining which gram
weight to use as the reference
amount. If there is not reference
amount for particular product refer
to
9 CFR 317.312 (c). |
-
Nutrient content claims are
incomplete or do not comply with
regulatory requirements, e.g.,
reference statement and
quantitative information of
comparative claims.
|
Refer to
9 CFR 317
313-317, 363 and
381.413-381.463
The Labeling of Factual Statements
on Nutrients in Meat and Poultry
Products
|
-
Undefined nutrient content
claims are used, e.g., leaner,
low carbohydrate, very low in
fat.
|
The
regulations are very prescriptive
for nutrient content claim; if the
claim is not defined in the
regulations then it cannot be used
on the label.
9 CFR 317 |
|
Last Modified:
July
15, 2010 |
|
|
|
|
 |
 |
|
|
|
|
|
 |
|
|
 |
|
|
|
|
|
To view PDF files you must have Adobe Reader installed on your computer.
|
|
|
|
|
 |
|
|
|
