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New FDA Labeling Requirements for 2020: Time to Comply

Well before the ball drops on the coming new year, food, beverage, and supplement manufacturers need to look carefully at the new FDA labeling requirements for 2020 and 2021. Now is the time to create new nutrition labels that comply with all the government’s new statutes.

Dr. Leonard McCoy, that acerbic but lovable Star Trek character, once observed, “The bureaucratic mentality is the only constant in the universe.” That goes double when it comes to nutritional labeling. Frankly, there are a lot of hoops to jump through.

However, 2021 looks to bring a little wiggle room – but only for those manufacturers with less than 10 million dollars in yearly food sales, according to the legal experts at JD Supra. However, for the rest of the industry, the FDA’s new labeling requirements represent “a significant change [in their] requirements for conventional foods and dietary supplements…”

While their intentions are good – to help consumers make better dietary choices – manufacturers must double-check the label copy that they send to their printers to ensure that all the products they sell on and after January 1, 2021 must bear the new, correctly printed labels.

Specific Changes in the FDA Nutrition Label Requirements

Specifically, the new FDA nutrition label requirements amend the former statutes that regulate labeling for products targeted for children under four years of age, as well as pregnant and lactating women. The new requirements also revise the appearance and format of each product’s label.

Although these statutes actually went into effect for larger companies on January 1 of this year, the government gave these manufacturers another year, given the COVID-19 pandemic and its resultant shutdowns in several regions of the US.

Additionally, the serving sizes, too, must change to reflect a more “realistic Reference Amounts Customarily Consumed (RACCs),” especially in beverages targeted to young children and babies. Other products, such as coffee beans, unsweetened tea and coffee, tea leaves, single-ingredient sugars, some bottled water products, dehydrated vegetables used as condiments, food coloring, and flavoring extracts.

Print Nutrition Labels Early to Avoid the Rush

If yours is a larger food, beverage, or supplement company, you need to move now to avoid the rush as the deadline looms larger. Smaller manufacturers, too, can get ahead of their competitors by complying with the new rules earlier than required.

Given the fact that many areas are now opening up from strict lockdowns, printers will likely have a glut of customers pouring in. Food, beverage, and supplement producers will have to face competition for their printers’ time from other industries, such as retail, the ever-growing sanitizer and hand soap industry, and of course, toy and cosmetic manufacturers during the holiday rush.

Smaller Companies: Check Where You Have Leniency, Says the FDA

Not all the newer statutes will fall under the FDA’s leniency rule. Those that do fall under its stipulations include minor formulation changes, according to the FDA.

These changes must meet the following criteria:

  • No difference in safety: Any ingredient that a manufacturer substitute must not cause an adverse health event. For that reason, it cannot aggravate any food allergies or sensitivities to sulfites, glutamates, gluten, or other similar substances.
  • Only tiny changes in quantity: The ingredient must not constitute more than two percent by weight of the complete food product.
  • Not a key or characterizing ingredient: The omitted or substituted ingredient must not be a key ingredient in the finished dish or food product. Of course, it must not affect the central focus of the food. For example, if a manufacturer substituted currants for raisins in raisin bread, it would not pass FDA muster, even with the more lenient rules.
  • Does not affect the maker’s claims: The substitution or omission of the ingredient must not affect “voluntary nutrient content or health claims” that the label states.
  • No significant nutritional effect: Substituting or omitting the ingredient on the label should not have a major impact on the nutritional value or functionality of the finished product.

So long as it meets the criteria listed above, it can affect the flavor slightly. For example, even though the omission of green peppers from a dish might affect the flavor a bit, it still can fly under the FDA’s radar during the pandemic and recovery, at least until the beginning of 2022. Similarly, manufacturers could substitute sunflower oil for canola oil, for instance, so long as the nutritional value is the same.

The FDA is also temporarily allowing flour manufacturers to substitute unbleached products for products labeled “bleached” due to the shortage of the chemical used to bleach flour.

Additionally, so long as the product simply labels an ingredient as “spice,” one spice can substitute for another. For instance, in such a product, a manufacturer could substitute nutmeg for cinnamon, so long as the product did not have “cinnamon” in its name.

During the pandemic, the FDA is allowing vending machine operators leniency in providing the caloric content of the foods they sell through their machines. However, the FDA advises, when possible, vending machine operators should provide their foods’ caloric content. Not only will it provide a better experience for its customers with the company’s honesty, but it will also help their customers make more healthful menu choices.

Other leniencies the FDA will provide during the coming year include food package and menu labeling, distributing eggs to retailers, and labeling eggs in the shell. Doing so can help one of the nation’s essential industries recover from the hit it took during the pandemic and support the entire nation in its recovery.

Food and Beverage Experience Essential in Your Choice of a Printing Company

In today’s shifting regulatory environment, it’s essential to use a printer with a wealth of experience and expertise in labeling foods, beverages, and nutritional supplements. At Nova Custom Printing, our design and printing teams have that experience. Familiar with all the regulatory requirements in that industry, we take the time to get your label right. To schedule your next label printing order, get in touch with the Nova team today.


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September 21, 2023

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July 31, 2023

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