Pressure Sensitive Stickers
|Pressure sensitive stickers are used as a means for manufacturers to use existing labeling material by covering inaccurate and/or misleading labeling information with corrected text or used as a promotional tool, e.g., a starburst encircling sweepstakes terminology. A pressure sensitive sticker must be the type that destroys the underlying label or package if removed, or be self-destructive.
Temporary label approval is not required when the entire label including the pressure sensitive sticker is truthful, not misleading, and the product is not misbranded. Corrected text on pressure sensitive stickers can cover mandatory or non-mandatory information.
Labeling bearing pressure sensitive stickers falls under the provisions of the generically approved labeling regulations 9 CFR 317.5 or 381.133, which indicates the conditions for use of final labeling without prior Washington approval. Companies need to create and maintain records of all final labeling, otherwise known as generic approvals.
Consistent with the rules on generic labeling, sketch labeling approval is required for the entire label when pressure sensitive stickers contain special claims (quality, nutrient content, health, negative, geographical origin, other claims (natural, animal production, e.g., "no antibiotics administered", breed claims, etc.)), guarantees, foreign language or a change of the nutrition facts serving size.
Transferred labels bearing a pressure sensitive sticker covering the existing legend, are operating under the original establishments final label approval record. When pressure sensitive stickers are used to cover and correct other existing information, the rules for sketch approval and generic labeling apply to the entire label.