Month: June 2019

Food Date Labeling

All packaged foods are required to bear labeling as per FDA regulations. There are mandatory elements of labels which must be present. Some elements of labels are not made mandatory by FDA, but some labelers may choose to adopt them.

Under the Federal Law, manufacturers of packaged foods are not required to place quality-based date labels on their products except for infant formula. Manufacturers may choose to voluntary put date labels on their product but as there are no uniform descriptions used on food labels for dating in USA, a wide variety of phrases are used for product dating such as “Use before”, “Sell By”, “Expires on”, “Best By” etc. to describe the dates to indicate when a food may be at its best quality. On survey in 2007, FDA found that most consumers are not able to distinguish between different date labeling phrases.

According to USDA, in USA, 30 percent of food is lost or wasted at retail or consumer level. This implies that about $161 billion worth of food is thrown away every year in USA. US FDA believes that food wastage is due to consumers fears about food safety and their misunderstanding of the meaning of terms on packaged food labels.

FDA has recently issued an advisory letter to the food industry supporting standardizing of voluntary date labeling if the date is simply used for quality not safety. Such standardization can provide consumers with information that is easy to understand.

FDA strongly supports manufacturers use of phrase “Best if used by” when they choose to apply a quality date label. This makes consumer understand that the date label is about quality of product not its safety and thus do not have to be discarded after the date if stored adequately. If the products have changed noticeably in color, smell or texture, consumers may avoid eating them.

To ensure your product labels are FDA compliant, you can use LMG’s label review service. Our experienced label team goes over each element of label with you in detail resulting in a fully compliant label.

Namrata

FDA Regulatory Consultant

support@libertymanagement.us

http://www.fdahelp.us

Published on: June 19, 2019

Who needs to register with FDA?

Owners, operators or agent in-charge of domestic as well as foreign facilities that are engaged in manufacturing, processing, packing or holding for human or animal foods for consumption in USA are required to register with FDA unless exempt from the requirement to register under 21 CFR 1.226.

Facilities that are exempt are:

  1. Farms
  2. Restaurants
  3. Retail Food Establishments e.g. grocery stores
  4. Nonprofit Food Establishments
  5. Fishing Vessels
  6. Facilities that manufacture/process, pack, or hold food entering US solely for the purpose of exportation or trans-shipment to another country
  7. Private residence of individuals
  8. Post Offices, Freight Forwarders

While registering a facility with FDA, the owner, operator or agent in-charge is required to provide accurate Facility info including the names of Emergency contact, Products, Trade names under which it conducts business and US Agent for the purpose of FDA communications. Also, owner, operator, or agent in charge provides an assurance that FDA will be permitted to inspect the facility at the times and in the manner permitted by the FD&C Act.

If a facility is required to register with FDA, they must register before beginning manufacturing, processing, packing, or holding operations in USA.

In addition to registration, all registered facilities are also required to renew FDA registration between Oct -Dec every even numbered year. FDA will consider a registration for a food facility to be expired if the registration is not renewed as required. Such registration will be cancelled and removed by FDA from its system.

Staring Oct 2020, FDA will mandate submission of UFI (Unique Facility Identifier) for all food facilities. This UFI will be required for all new registrations as well as registration renewals. FDA will not confirm your registration or provide you with a registration number until FDA verifies the accuracy of your facility’s UFI and verifies that the facility-specific address associated with the UFI is the same address associated with your registration.

Liberty Management Group Ltd provides assistance with FDA Registration, Biennial Renewals, US Agent service and many other FDA regulations.

Namrata

FDA Regulatory Consultant

support@libertymanagement.us

http://www.fdahelp.us

Published on: June 06, 2019