Module 3

Food Labeling Fundamentals

Dr Muhammad Nadeem

FT-518
Food Labelling
Course Learning Objectives
The main objectives of this course include:
◼ Understand the basic food labelling requirements,
essential for all types of food products.

◼ Understand the importance of labelling allergens

correctly.

◼ Knowledge of what can and cannot be printed on food

packaging in relation to nutritional and health claims.
Course Learning Outcomes

◼ Interpret relevant food and drink labelling legislation

and know when to seek advice.

◼ Understand how to implement current food and drink

labelling legislation in order to generate compliant
labels.

◼ Recognize compliant and non-compliant labels.

Authority for Food Labeling

◼ Food Drug and Cosmetics Act 1938

◼ Fair Packaging and Labeling Act1966

❑ Consumer Commodity
◼ “Any commodity that is customarily produced
or distributed for retail or consumption by
individuals for personal care and the
performance of household services and, that
is generally consumed or expended within the
course of its use.”

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Major Labelling Requirements

1. Mandatory labeling of the name of the food,

ingredient statement, net quantity, and the name and
address of the manufacturer or distributor.
2. Mandatory standards of identity.
3. Labeling of imitation foods.
4. Nutrition information for special dietary foods.
5. Prohibition of any false or misleading claims.

▪ FDA’s labeling regulations are located in 21 Code of Federal Regulations

(C.F.R.) 101 and cover both the requirements of the Food, Drug, and Cosmetic
Act and the Fair Packaging and Labeling Act
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Imitation Should Say Imitation

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For Instance: KRAB Meat

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Food Labeling – Misbranding

▪ Misbranding
▪ Material Facts
▪ “False or misleading in any particular”
▪ Offered for sale under another name
▪ Defined label
▪ Food labeling not based on safety but on consumers
need for information

▪ Section 403(a)(1) of the Federal Food, Drug, and Cosmetic Act (FD & C Act) deems a
food misbranded if the labeling is false or misleading “ in any particular. ”

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Misbranding

▪ Misbranding = Presence or absence of information

on label of a product which is false, deceptive or
misleading.

▪ Regulation of labeling concerning the presence or

absence of specific attributes of a food product has
great potential impact on food market.

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Misbranding (Contd.)

▪ If it is offered for sale under the name of another food

▪ If it is an imitation of another food, unless its label bears, in

type of uniform size and prominence, the word
“imitation” and, immediately thereafter, the name of the
food imitated.

▪ If its container is so made, formed, or filled as to be

misleading

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Misbranding (Contd.)

▪ If it purports to be — or is represented as a food

for which a definition and standard of identity has
been prescribed by regulations, unless:
(1) It conforms to such definition and standard, and
(2) Its label bears the name of the food specified in the
definition and standard, and, insofar as may be required by
such regulations, the common names of optional
ingredients (other than spices, flavoring, and coloring)
present in such food.

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Misbranding (Contd.)

❑If it purports to be or is represented as:

▪ A food for which a standard of quality has been prescribed by

regulations, and its quality falls below such standard, unless its
label bears, in such manner and form as such regulations specify,
a statement that it falls below such standard; or

▪ A food for which a standard or standards of fill of container have

been prescribed by regulations, and it falls below the standard
of fill of container applicable thereto, unless its label bears, in
such manner and form as such regulations specify, a statement
that it falls below such standard.

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U.S. v 95 Barrels of Apple Cider

▪ Douglas Packing Company of Fairport, New York State.

▪ Excelsior brand vinegar labeled, “Pure Apple Cider
Vinegar – made from selected apples”.
▪ In actuality, the vinegar was made from dried (80% water
removed), and then rehydrated apples.
▪ Defendant alleged similar quality regardless of the origin.
▪ U.S. Supreme Court said, “If the article is not the
identical thing that the label indicates, it will be
misleading to consumers and therefore misbranded”.
▪ Use of barium chromate to neutralize sulfur fumes
(used as a preservative), also a major problem.
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U.S. v 95 Barrels of Apple Cider

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