Given the fragile state of the food industry and the high demand for shelf-stable products on behalf of the consumer during the COVID-19 pandemic, the FDA has loosened their strict guidelines on minor ingredients that do not contain any of the top 8 food allergens. In short, the FDA is allowing manufacturers to change their product recipes allowing some nutritional discrepancy on the labels in regard to small ingredients that must be changed due to their lack of availability as a result of sourcing difficulties. So what does this mean for you and your product labels? We’ve got the highlights.
Per the FDA guidance for the industry released just this past week, a temporary grace period will be extended to manufacturers needing to change minor ingredients within their product recipes and they will not be penalized for small discrepancies in nutrition reporting. However, there are parameters to the FDA’s flexibility:
- Safety – minor changes to the product recipe must not pose any threat to the consumer’s health and safety. The product must be free of the top 8 allergens, including derivatives of gluten. We also recommend a thorough understanding of any cross contamination risk that might be associated with any substitute ingredient that is used in placed of the regular product ingredients.
- Prominence– changes must be less than 2% of the product weight. Ingredient changes that are substituted that exceed this value may pose too large of a nutritional discrepancy for product labeling.
- Characterizing Ingredient MUST NOT be substituted. A characterizing ingredient is the prominent ingredient within a recipe that provides the name of the recipe. For example, it is unacceptable to substitute bananas in “banana bread”. The Banana is the characterizing ingredient that provides the recipe name based upon it’s primary presence within the recipe.
- Claims– the omission of an ingredient must not contradict any health claims that are advertised on product packaging. The FDA strictly regulates health claims that are reflected on product packaging. The product recipe has to abide by these regulations to the letter. For this reason, if a product advertises that it is low in fat, but the recipe change brings the total fat value above the amount of fat that the FDA has stipulated as being within “low-fat” parameters, it is not a viable substitution and can’t be used.
- Nutrition/Function– an ingredient substitution must not significantly alter the nutritional values reflected on the product label, nor the functionality of the nutrients. For example, if the original recipe of a whole grain bread uses wheat flour (which is high in fiber) and substitutes 1/2 the normal measurement of whole wheat flour for unbleached organic all-purpose flour, the fiber content and the functionality of the product nutrients would be significantly altered. As a result, the change would be too significant to omit on a product label.
Whether you are able to take advantage of the FDA’s flexibility during COVID-19 or not, it is important to be accurate. Rapid changes in product ingredients to meet consumer demand requires a platform that can provide instantaneous nutrition reporting. Although you may not need to change your current product label, you will need to perform a nutrition analysis to confirm that you are abiding to the regulations set by the FDA regarding this temporary grace period.With our 300,000 + ingredient database, LabelCalc makes it easy to swap ingredients within your product recipe.
For example, if you usually use Heinz tomato sauce as the base for your BBQ sauce but your supplier only has hunts available, in a few clicks of a button you can determine if the swap fits within the FDA guidelines or calls for a new nutrition label. Simply pull up Hunt’s tomato sauce, provide the appropriate measurement for your product recipe and insert right into your existing recipe to run the nutritional report. You can create as many recipes as you like, using different types of tomato sauce until you find one that suits your recipe best. Don’t wait for a lab when you can get instant results.
Need to update your recipe? Get started today with LabelCalc. And if you need a new label, the first one is on us! Try it free here.