On The Menu’s predictions for 2008:

10. Heart healthy food. An old standby, heart healthy stays in the ranks. America’s number one cause of death is still heart disease. We expect to see continued labeling of heart-healthy (low-fat, trans fat free, lower sodium, high-fiber) foods and menu items.

9. Fair trade food. People will give more attention to how food is produced and give ethical consideration to their purchases.

8. Medicinal food. Watch for foods promoting digestive health, brain function, weight management and beauty.

7. 100 calorie snack pack food. We’ll see more convenience food individually packaged based on the caloric content.

6. Gluten- and allergen-free food. In the three years since we began helping restaurants create gluten-free menus, we’ve seen this trend take off. It’s a win-win for food companies and their customers. Note: FDA’s final definition for “gluten-free” will be announced later this year.

5. Healthy kids’ food. Efforts gain momentum to address the obesity epidemic among children. School and restaurant meals will offer healthier choices. Foods marketed to kids will emphasize less sugar and fat, more whole grains and real fruits and vegetables.

4. Local, sustainably grown food. Organic will continue to be big, but emphasis will be on locally grown foods from sustainable farms.

3. Nutrient dense, real, whole food. Foods that are fortified will fall out of favor to foods that have been minimally processed and are naturally nutrient dense. Manufacturers will make efforts to produce foods free of hydrogenated oils, artificial colors and flavors, high-fructose corn syrup and preservatives.

2. Whole grain food. Not to be found just in bread; we expect to see more whole grain pastas, cereals, crackers and cookies join the movement (no pun intended).

1. Marketing of restaurant food. Nutrition information on restaurant foods will be expected by customers who are more mindful of their eating. Legislation continues to grow in this arena. In Colorado check out the Smart Meal Seal. We believe 2008 is just the tip of the iceberg (pun intended).

A study conducted by The Hartman Group, Inc. shows a rise in food label reading by consumers. In their “Pulse Report: Label Reading from a Consumer Perspective” they examined the levels of consumer awareness, familiarity and trust of 13 different food, wellness and sustainablity related symbols and icons used in the marketplace today. The results show:

• 30% of Americans report they read labels much more frequently today than a year ago.
• 31% say they are reading labels slightly more often.
• 36% say they are reading them at about the same rate.
• Only 4% are reading labels less often than a year ago.

Your customers have come to expect labels on food products - an investment well worth making.

Have you ever unveiled the mask of the Code of Federal Regulations (CFR)? It can be frightening trying to make your way through these daunting documents. Some of the text is so terrifying - it may seem you need a law degree to decipher it.

Title 21 of the CFR refers to food and drugs, and Part 101 pertains to food labeling. At On The Menu, LLC we take the chill out of the blood curdling regulations laid open before you. If you need guidance up the rickety ladder of food labeling please contact the experts. We will take the “boo” out of this scary story leaving you smiling.

Happy Halloween!

Julie and Rebekah

We often hear confusion over the U.S. Food and Drug Administration’s (FDA) requirement to display the name and place of business of the manufacturer, packer or distributor on packaged food products. Plain and simple, this information is mandatory and the FDA has specific guidelines on how it should be listed.

The name and place of business should be clearly displayed on the Principal Display Panel or the Information Panel.

It is acceptable to list a manufacturer or distributor if the food is not manufactured by the business named on the label. In this case, factual terms such as “Manufactured by” or “Distributed by” should be used.

The place of business must include a street address, city, state and zip code. The street address can only be omitted if the business is listed in the current telephone directory and an interested party can find the business within a reasonable effort. The city, state and zip code must still be present even if the street address is omitted. Post office boxes are not acceptable substitutions for street addresses.

Additional information, such as phone numbers and websites can be included, but are not required.

Please refer to the Code of Federal Regulations, Title 21, Part 101.5 for details or contact On The Menu, LLC.

The Food and Drug Administration (FDA) allows modified formats of the standard Nutrition Facts food label. One of the recognized formats is a dual declaration or dual listing label. This label provides nutrition information on a product prepared, served or consumed in two ways. A dual declaration label is commonly seen on dried mixes, such as cake, soup or macaroni and cheese. It is also frequently used with cereal and sometimes used to denote various serving sizes.   When using a dual declaration label for a dried mix (see Figure A), the first column shows nutrition information for the product as purchased and the second column shows nutrition information for the product prepared as directed on the package. Figure B illustrates both dry cereal and cereal served with milk. Figure C shows a food consumed in two different serving sizes. In this case it is a single serving bag of chips with nutrition information for both the FDA reference weight (30 g) and the entire bag.  Your customers will appreciate the additional information they receive from a dual declaration label. For help with a dual or other format Nutrition Facts food label, please contact the experts at On The Menu, LLC.

Figure A

Figure B

The Food & Drug Administration (FDA) defines two panels on a food package. They are the Principal Display Panel (PDP) and the Information Panel (IP).  

The Principal Display Panel is the portion of the package label that is most likely to be seen by the consumer at the time of purchase. It is the panel that is so obviously displayed at the grocery store. It is the front of a box (like most cereals) or jar (like most peanut butters), but it can also be the top of a box (like cream cheese) or the top of a carton (like sour cream or eggs). The Information Panel is immediately to the right of the PDP as displayed to the consumer.

There are six items that should be located on these two panels. In a blog (dated March 27, 2007) we discussed the “Six Big Labeling Requirements” of food manufacturers. To review, they are:  

1. Statement of Identity
2. Net Quantity of Contents
3. Nutrition Labeling (exemptions may apply to this requirement)
4. Ingredient Statement
5. Allergen Declaration
6. Name and Place of Business of Manufacturer, Packer or Distributor

All six items can be located on the PDP, although it is unlikely because of space constraints or visual appeal. The first two items, the statement of identity and the net quantity of contents, must be located on the PDP.  Typically the nutrition label, ingredient statement, allergen declaration and name and place of business are found on the IP, although it is not required. If there is insufficient space, they can be put on any other panel or space on the packaging. Whichever panel you decide to place the nutrition label, ingredient statement and allergen declaration, they must appear together with no interrupting material. 

For more information or assistance with your food labels, call the experts at On The Menu, LLC.

Consumers enjoy a variety pack of food—not only for the choice it affords them, but the ability to sample different flavors without the investment of a larger quantity of a single food item. Do you have food products that are multi-flavored that would benefit from being packaged together?   Perhaps you should consider combining multiple varieties of food items into one package. Common foods that are packaged together include multi-flavored snack bars, ice cream novelties, single-serving breakfast cereals, popcorn, etc. Rather than having a separate Nutrition Facts label for each food product contained in a package, the U.S. Food and Drug Administration (FDA) allows a modified format called an aggregate label. This not only conserves on labeling space but provides a clear and concise format of displaying nutrient information to your consumer.  Although an aggregate label looks different, it follows the same FDA labeling rules. For example an aggregate label must provide nutrition information for each assorted food product contained in the package. Below is an example of an aggregate Nutrition Facts label showcasing nutrition information on three different granolas. Please note: a separate ingredient and allergen statement is required for each food item.

For help with an aggregate or other format Nutrition Facts food label, please contact the experts at On The Menu, LLC.

Not all businesses are required to label their food products. However, even if you are exempt, you may still want to consider nutrition labeling for your product. Here are five compelling reasons why:

1. Nutrition analysis gives you insight into the nutrition profile of your product. This is helpful for understanding your food product and its nutrient makeup.

2. Your customers want you to label your foods. The majority of consumers read labels and have come to expect this information on food products. In fact, it is said that at least 80 percent of women read food labels. The information is useful for their purchasing decisions and consumption choices.

3. Providing Nutrition Facts labels on your products allows you to make nutrient content claims if your food qualifies. You cannot make a claim without a label.

4. Nutrition labeling can give you a competitive advantage. It gives you a professional edge and allows you to be a player in the marketplace.

5. Nutrition labeling gives you the ability to market your food product. Nutrition “sells” to today’s consumer.  

Nutrition analysis and labeling is well worth the investment. Don’t delay—get your food label today!

Does your food packaging meet the six big requirements outlined in the Federal Food, Drug and Cosmetics Act, the Fair Packaging and Labeling Act and the Food Allergen Labeling and Consumer Protection Act? Let’s get up to speed on the requirements:

1. Statement of Identity
2. Net Quantity of Contents
3. Nutrition Labeling
4. Ingredient Statement
5. Allergen Declaration
6. Name and Place of Business of Manufacturer, Packer or Distributor

The statement of identity is the common or usual name for your food product as defined by law or regulation. You can determine your proper statement of identity for your product in the Code of Federal Regulations, Title 21, parts 102 and 130-169. If your food is unique and has not been identified, you can give it a name that accurately and appropriately describes it. 

The net quantity of contents is the weight or fluid measurement of food as it’s sold in its retail package. The net quantity must be shown both in
U.S. customary system (pounds, ounces, fluid ounces) and metric terms (grams, kilograms, milliliters, liters). If your product exceeds one pound, you must state the weight in both pounds and ounces. For example, if your product weighs 20 ounces, you must state it as 1 lb 4 oz. The metric term is placed in parentheses following the
U.S. customary term. In addition, you must say “net wt” or “net” (for fluid measurements) prior to the measurement. Here are some examples:

• Net Wt 1 lb 4 oz (567 g)
• Net 8 fl oz (237 mL)

Nutrition labeling is displayed in a Nutrition Facts panel. A Nutrition Facts panel has three components: serving size, nutrient values and a footnote. Depending on the nutritional makeup of your food and it’s packaging, there are several options available. The most common FDA approved label is a “standard” Nutrition Facts panel, which is a vertical panel containing all three components. Other formats include: tabular, dual declaration, aggregate, simplified and shortened. Some food manufacturers are exempt from nutrition labeling under the small business exemption amendment. 

An ingredient statement is a listing of all ingredients used to fabricate a food. The ingredient must be listed as a common or usual name. The ingredients must be listed in descending order of predominance by weight (from greatest to smallest). Multi-component ingredients must list ingredients in parenthesis. For example if your product uses margarine, you must list in parenthesis all ingredients in the margarine. Special rules apply to spices, flavorings and colorings. 

An allergen declaration came into effect in January 2006. It requires food manufacturers to declare if their product contains one of the eight major allergens. The eight major food allergens include:

• Wheat
• Milk
• Soy
• Eggs
• Peanuts
• Tree nuts
• Fish
• Crustacean fish

Allergens can be listed in the ingredient statement or in a separate declaration statement. Tree nuts, fish and Crustacean fish must be listed by type. For example, you should list allergen as containing “pecans,” “tuna,” “shrimp,” not “tree nuts,” “fish,” or “Crustacean fish.”  

And finally, the last of the big requirements is the name and place of business of manufacturer, packer or distributor. You must include:

• Name of manufacturer, packer or distributor
• Street address (if not listed in current phone directory)
• City
• State
• Zip code
• Phone number or website address (optional)