What small scale producers and growers need to know about labeling and 2 tips to help you succeed.
Mis-labeled product is the number one cause for recalls.
For the past few years, the number one cause for FDA food recalls in the USA was mis-labeled products. Most of these were due to the producer not labeling an allergen properly. There are other reasons for your label to cause a recall, misbranding, health claims, and improper format are all causes for your business to get in rocky waters with regulators, customers, and of course, consumers.
Your food label is often the first time you have a chance to interact with your consumer. What you say in that one-way communication can make or break your company’s success. You’ve worked hard, put in the hours and have a great product that customers want to sell, and consumers want to enjoy. The packaging and label of your product must stand out from the sea of other like items. I remember getting our hot sauce brand into retail locations was hard, only to find out they would put us on the bottom of the shelf or in another undesirable location.
Our label, like yours had to pop and stand out especially as a new product. But, designing a great label is more than just choosing a catchy name and fun colors, there are FDA mandates that must be followed. The first mistake we see with small producers is not understanding that the FDA mandates certain label requirements. Font size and locations of material on your label are common mistakes that happens even with very large companies. This can lead to a few things being required of you, at best having to pay to redesign your label, or if the mistake is bad enough you may have to destroy your inventory of labels that are purchased. Worse case, you may have to recall product that has already left your control. Obviously, all three of these scenarios are not good for your brand, reputation, or consumer confidence. With a small producer, this could even cause stores to drop your product and allow your competitors to take over market share you just earned.
What can you do about this? We suggest making a check list. Go through each label and ensure that all the points are touched on, is the nutrition facts panel on the right side of the Principle Display Panel? Are you using a fanciful name appropriate with the common or standard name of the product? Do we meet the standards to be called a particular name? For example, the FDA describes a cherry pie, if you don’t meet that requirement you can’t use that name.
Unfortunately, the biggest cause for concern with labels is also the number one reason for recalls. Allergens. Companies of all sizes make this mistake and your company is no exception. Unless you have a system in place to ensure that your ingredient list is accurate and that it reflects all allergens that may be present in your product(s) you may miss allergens on your label. There are many causes as to why an allergen isn’t claimed on the label but having a robust system that starts with procurement and ends with shipping to your customer or consumer is key. Once you have developed your allergen control program at your facility you are lessening your chances of having an undeclared allergen in your product, but mistakes happen and it’s your job to ensure the ingredient statement label is correct.
What is one thing to help ensure the accuracy of your ingredient statement? Understand the sub-components of your raw material. Once you have your final formulation for your product, reviewing each of those sub-components ingredient lists to ensure nothing was missed on your final product’s ingredient list is a crucial step in ensuring your labels accuracy. The other thing to watch for, especially as a small supplier, is the changing of raw material suppliers. Your raw material vendors often change based on cost, availability, size, etc. but the sub-components need to remain the same or your final product’s label needs to change. This is a valuable item to remember when considering a raw material supply change. Even simple raw materials may have acids, or other items that may change from brand to brand.