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"?
     
• Ingredient 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?

• 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)?

• 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

 ( 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

• 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

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.