Retail Labeling Req's

the business of coffee houses

Retail Labeling Req's

Postby PatrickSmith on Wed Jul 06, 2011 6:03 am

We are looking to redesign our retail labels, and I want to make sure we're meeting all of the necessary req's. Trouble is, I am having a hard time finding specific req's. I assume something like "454 grams roasted arabica coffee" but are there other labeling requirements of which I am unaware? Any guidance would be greatly appreciated.
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Re: Retail Labeling Req's

Postby taylormork on Mon Jul 25, 2011 7:43 pm

FDA has been known to inspect coffee packages on market shelves and also pop into roasteries to check on their packaging (even if not part of a site visit for other FDA site requirements). They mainly check for net weight and the detail of company information. FDA often complains to roasters that full/street address is not listed on a package, although their requirements state that this only needs to be listed if the business is not listed in any "city directory." In today's world, I wonder if online directories such as google business listings count? Gotta get Marshall in on this discussion!

FDA's main doc on this matter: "Guidance for Industry A Food Labeling Guide"

Regulations re: volume and company information
NET weight must listed on the front label i.e. side of package most likely to be seen by customer at time of purchse
8. What name and address must be listed on the label?
Answer: Food labels must list:
Name and address of the manufacturer, packer or distributor. Unless the name given is the actual manufacturer, it must be accompanied by a qualifying phrase which states the firm's relation to the product (e.g., "manufactured for "or "distributed by").
Street address if the firm name and address are not listed in a current city directory or telephone book;
City or town;
State (or country, if outside the United States); and
ZIP code (or mailing code used in countries other than the United States).

Regulations re: the term "fresh"
(a) The term “fresh,” when used on the label or in labeling of a food in a manner that suggests or implies that the food is unprocessed, means that the food is in its raw state and has not been frozen or subjected to any form of thermal processing or any other form of preservation, except as provided in paragraph (c) of this section.

labeling "low acid" has become popular but I'm not sure of the requirements. A quick search turned up thisbut it's not clear:
N25. When is a formulated food considered to be specially processed and permitted to bear a "low" or "free" claim?
Answer: If a similar food would normally be expected to contain a nutrient, such as sodium in canned peas, and the labeled food is made in such a manner that it has little or none of the nutrient, then the food is considered specially processed and may bear a "free" or a "low" claim. 21 CFR 101.13(e)(1)

As far as I understand, coffee is not officially considered a perishable item so "best by" dates, if any, are really the decision of the roaster and depend on how the roaster wants to manage its image with regard to quality promotion. However, I have not seen official guidance on that issue and thus may be misinformed.
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Re: Retail Labeling Req's

Postby Marshall on Fri Aug 05, 2011 10:28 pm

The labeling requirement that concerns most food precessors comes from the FDA nutritional labeling regulations. But the FDA has exempted coffee from this requirement, unless special nutritional claims are made. Specifically, FDA Reg 21 CFR 101.9 includes this exemption:

Foods that contain insignificant amounts of all of the nutrients and food components required to be included in the declaration of nutrition information under paragraph (c) of this section, Provided, that the food bears no nutrition claims or other nutrition information in any context on the label or in labeling or advertising. Claims or other nutrition information subject the food to the provisions of this section. An insignificant amount of a nutrient or food component shall be that amount that allows a declaration of zero in nutrition labeling, except that for total carbohydrate, dietary fiber, and protein, it shall be an amount that allows a declaration of “less than 1 gram.” Examples of foods that are exempt under this paragraph include coffee beans (whole or ground), tea leaves, plain unsweetened instant coffee and tea, condiment-type dehydrated vegetables, flavor extracts, and food colors.
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