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Web Content Viewer (JSR 286)

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Web Content Viewer (JSR 286)

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Web Content Viewer (JSR 286)

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Label Submission Checklist

 
Table of Contents

Label Sketch


Label Sketch

Are the up-to-8 required features on the label? Are they in the required locations according to 9 CFR 317 and 381, Subparts N and Y, and consistent with the food standards in 9 CFR 319 and 381, Subpart P?
  • Product Name ( 9 CFR 317.2(c) and 381.117)
    • Is there an accurate product name?
    • Does the name invoke a standard?
    • Is that standard met, i.e., is it shown, through the formulation and processing procedures, that the standard is met? For example, 9 CFR 317.312 "Beef in Barbeque Sauce" requires 50% cooked beef that is cooked to yield 70% or less. If the beef is injected, the yield is from the green weight of the un-injected beef.

  • USDA Inspection Legend ( 9 CFR 312.2, 317.2(i), 381.96)
    • Is there an inspection legend on the label?
    • Is the correct legend used?
    • Is the correct plant number used?
    • If dual legends are used, is the product HRI only?
    • Is the Establishment # in the legend, if not where is it?

  • Net Weight ( 9 CFR 317.2(h), 381.121)
    • Are the size, spacing and location correct?
    • If no net weight, did you stipulate net weight applied at retail?

  • Handling Statement ( 9 CFR 317.2(k), 381.125(a))
    • Is the handling statement appropriate?
    • Is the handling statement supported by processing procedures?
    • Does the handling statement conflict with claims, i.e., "fresh"?

  • Address (Signature) Line ( 9 CFR 317.2(g), 381.122)
    • Is a zip code included?
    • Is the address line contiguous to the ingredients statement on the information panel?
    • Does the signature line require "Distributed by" or "Packed for"?

  • Ingredients Statement ( 9 CFR 317.2(f), 381.118)
    • Are all multi-ingredient components sublisted?
    • If the product is an import, are all spices/natural flavors identified by their common or usual name in the formula?
    • Is the order of predominance supported by the formula?
    • Is the ingredients statement presented as components (i.e., with component ingredients sublisted) or as a composite of all ingredients?
    • Are common or usual names, not brand/trade names, used in the formula?

  • Nutrition Facts ( 9 CFR 317.300 - 317.400, 381.400-381.500)
    • Is the correct RACC used for the serving size?
    • Is the serving size correctly stated?
    • Does rounding of nutrients meet requirements?
    • Is the format correct (i.e., full, simplified, or tabular)?
    • Are claims supported by the numbers?
    • Is the "servings per container" accurate and not "varied," if the product bears a net weight?
    • Do bone-in products indicate percent bone?
    • For bone-in products, is the "serving size X servings per X" statement accurate? Bone/inedible portion is not included in the nutrition information.

  • Safe Handling Instructions (SHI) ( 9 CFR 317.2(l), 381.125(b))
    • Are the current SHI included when necessary?
    • If the SHI are modified in accordance with regulations, are there specific handling instructions on the label to support the modification?
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USDA/FSIS Label Submission Form 7234-1

  • Is the product amenable to the FMIA or PPIA?
  • Does the product contain at least 2% cooked or 3% or more raw meat or poultry?
  • Is the product for human consumption or a certified pet food?
  • Is the approval (application) form submission complete, i.e., form completely filled out, with the required number of copies? [Generally 2 copies are needed; however, 3 copies are needed for export/import labels and labels with Child Nutrition, and organic/animal production claims.]
  • Is the submission legible, and does the product formula have percent or weights that are totaled at the bottom?
  • Does the submission provide a size for the PDP and total available labeling space?
  • Does the processing procedure support any claims/statements made on the label?
  • Is the product smoked, and is the source of smoke indicated (e.g., Hickory)?
  • Is the product sliced, ground, formed, etc.?
  • Is the product dried? -- is the MPR provided?
  • If a cooking temperature is provided, is it appropriate?
  • Is a percent pick-up of solution/breading/coating stated?
  • Is the product Ready to Eat (RTE) or not RTE (nRTE)? Is an explanation provided for nRTE products that appear to be RTE?
  • Does the formula match the ingredients statement? Tips:
    • Chicken is not chicken breast meat
    • Chicken meat is not chicken tender
    • Chicken tender is not chicken tenderloin
    • Beef is not veal
    • Pork trimmings are not bacon
    • Angus is not Black Angus
  • Is the formula presented in the same units adding to "100%" or all in pounds (not a mix of pounds and ounces)?


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Common Mistakes on Label Submissions

  • No sublisting of multi-ingredient components on the label
  • Percent restricted ingredients not provided or supported in submission (e.g., the percent of fat in the product is required for some ingredients)
  • Binders in the solution pumped in meat or poultry products are not included in product names/qualifiers
  • Order of predominance of ingredients is wrong
  • Geographic claims and styles not supported by data
  • Nutrition claims not supported by data or permitted by regulations
  • Not enough copies of submission forms
  • Submission is not legible (labels or application)
  • Reason for a temporary label approval is not supported by required information (see below)
  • Product name prominence/letter size conflict with requirements
  • Meaningful terms/claims are not validated on the application, e.g., #1 seller of franks in the West is not supported by data

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Temporary Approval Requests ( 9 CFR 317.4/ 317.9, 381.132)

  • Specify the problem that has caused the need for a temporary label
    • If the reason is a formula change, provide new nutrition profile
    • Specifically list ALL ingredients in the product formulation and NOT on the label
  • Additional information required by the Federal meat/poultry inspection regulations for granting a temporary:
    • support that the label error does not misrepresent the product
    • support that the label error does not pose any health, safety or dietary problems
    • support that denial of the temporary approval would create undue economic hardship
    • support that granting the approval does not give the manufacturer an unfair competitive advantage


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Common Abbreviations in Comments on Label Submissions
  • IS - Ingredients Statement
  • PN - Product Name
  • NF - Nutrition Facts
  • SS or S/S - Serving Size
  • S/C, SC or S Per - Servings per Container
  • RACC - Reference Amount Customarily Consumed
  • NW or Net Wt - Net weight, usually size, spacing or location problems
  • HS - Handling statement
  • SL - Signature (Address) Line
  • OOP - Order of Predominance in the ingredients statement
  • RTE - Ready-to-eat
  • NRTE --Not ready-to-eat
  • MPR - Moisture protein ratio
  • HRI - Hotel, Restaurant, Institution

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Additional Information Sources

Need additional information? Contact the Agency's Labeling and Program Delivery Division which provides guidance, policies and access to the Federal meat and poultry inspection regulations.

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Last Modified Mar 19, 2014