USDA Food Safety and Inspection Service
Table of Contents
- Required Information on a Label
- Company Responsibilities Regarding Labeling
- Generic Approvals
- Labeling Terms
- Food Handling
- Protective Covering
The following information is quoted from USDA officials regarding US food safety and inspection service.
Required Information on a Label
There are up to 8 required features including:
- Product name
- Inspection legend and est. number
- Handling statement
- Net weight statement
- Ingredients statement
- Address line
- Nutrition facts Safe handling instructions
It is important to ensure that food is properly labeled so it is not classified as misbranded. This can look like: labeling is false or misleading, if it is offered for sale under the name of another food, or if it is an imitation of another food without the proper labeling.
There is a specific order in which product labels are able to get approved by the USDA. Prior approval will be needed for all product labels. The company has to include a sketch submitting proof of showing all labeling material.
Company Responsibilities Regarding Labeling
It is necessary to create a record of all final labeling including sketch approved labels. The company must also maintain labeling records including final labeling and temporary approvals.
Temporary approval can be provided of non complying labels under circumstances for up to 6 months, only if:
- The label is not misleading
- The label does not pose any health, safety, or dietary problem
- Approval would not give an unfair competitive advantage
- Denial would cause undue economic hardship
There are many classifications for products to receive generic approvals regarding new labels. These classifications are specific to each product and are all outlined below.
- Standardized products without special claims, guarantees or foreign language
- Single ingredient products without special claims, guarantees or foreign language
- Products with contract specification for Federal Government agencies
- Shipping containers
- Inspection legends
- Products not intended for human food
- Poultry heads and feet for export for processing as human food
- Consumer test products not for sale
- Inserts, tabs, liners, pasters, etc. that make no reference to the product
- Prior approved sketch labeling or labeling with generic modification
There are also rules regarding generic modifications to a product label. These modifications should be reported to the USDA and include:
- Proportionate enlargement or reduction
- Abbreviations for unit of measurement
- Master or stock label
- Holiday designs
- Opening instructions or serving directions
- Coupons, cents-off statements, cooking instructions, packer product code information or UPC information
- Address of packer, manufacturer or distributor
- Net weight statement
- Recipe suggestions
- Newly assigned or revised establishment number for a particular establishment
- Open dating information
- Packaging material
- Brand name changes
- Deletion of the word “new”
- Handling statements
- Safe handling instructions
- A change in the quantity of an ingredient without order of predominance change
- Color changes
- Vignette changes
- Addition, deletion or substitution of USDA poultry grade shield
- Deletion of a claim or non-mandatory information or features
- Deletion or addition of English language translated into foreign language – for export only
- Quantitative adjustments to the nutrition facts except for serving size
- A change in establishment number by a corporation for a plant under its ownership
- The use of the term fresh on poultry carcasses or parts
- The use of the term frozen on poultry carcasses or parts
It should be acknowledged that the terms of labeling changes with each food product. Make sure to be following each of these specifically outlines for the type of food including meat, fresh items, spring lamb, and production type. The guidelines regarding each classification are outlined below:
“‘Meat’ is defined as the muscle that is skeletal, or in the tongue, diaphragm, heart, or esophagus…” (9 CFR 301.2(rr)). This includes products recovered from “advanced” meat recovery systems (AMR) machinery. This classification does not include “mechanically separated” meat.
Fresh items may not be used to designate a product that contains sodium/potassium nitrate/nitrite or has a brine concentration of 10% or more. They also may not be used to describe poultry carcasses or parts when the internal temperature has ever been below 26o F.
Spring lamb is considered to be the carcasses of new-crop lambs slaughtered in the Northern Hemisphere. It should be gathered during the period beginning in March and ending the close of the week containing the first Monday in October.
Production refers to the making or manufacturing of components or raw materials. Food items that are from the “Farm” or “country” should not be used on labels if the products are not prepared in the farm or country. This also applies to sausage that contains cereal because it should not be labeled as “farm style” or “country style”. There are also other easy to classify the production of an item and where it comes from. This includes: free range, farm raised, no added hormones, no antibiotics administered, not fed animal by-products, and “Certified organic by (name of certifying entity” – until 8/20/2002.
There are multiple instructions regarding mandatory handling of foods. This includes the statements that are used to instruct consumers on how to store the item, or based on how the food item was processed. For example; perishable products are preserved by chilling and should read “Keep Frozen”, “Keep Refrigerated”, or “ Keep Refrigerated or Frozen” on the package. For perishable cooked products, they should be shipped hot and ensure the proper treatment was asserted before shipment such as the product receiving a heat lethality treatment, or a label reading “This product must either be maintained at no less than 1400 F during shipment or discarded”.
Food handling instructions should also be apparent on the labeling. This labeling is mandatory when meat and poultry products are raw or partially uncooked. The instructions should have a specific format for word size as well as mandated graphics.
All labeling should be instructional for the merchant and consumers. It is important to label when a product is not ready to eat so consumers are aware of this before purchasing. This includes:
- Products containing a meat or poultry component that has received a lethality treatment for pathogens.
- Dry or cured products, e.g. Country ham.
- Products containing non-meat/poultry components in need of a lethality treatment including: meals, dinners and frozen entrees.
- Product cooking and preparation instructions on the product that are sufficient to destroy pathogens.
- Terms required on principal display panel displayed in a prominent manner in product name, in a starburst or elsewhere on principal display panel
- Ready to cook
- Cook before eating
- Cook and serve
- Needs to be fully cooked
- Safe handling instructions are recommended
Protective coverings on processed meat products are immediate packaging exempt from labeling requirements; no marking or labeling is permitted except for limited situations. With products like these the shipper must include all mandatory features since it is the immediate container with a statement of limited use required on the shipper. It also has some limitations when it arrives at the area it is going to be consumed at the premises with no further distribution.
When poultry is the product presented in protective coverings the process is as follows for export or if it is sold in hotels, restaurants or institutions are exempt from the mandatory labeling of immediate containers except for limited situations. The shipper must include all mandatory features since it is in the immediate container. Although, the shipper does not require a statement of limited use.
For unprocessed meat cuts the labeling requirements are different. The shipper must include all mandatory features on it since it is in the immediate container. Different from unprocessed meats, the products may be removed for resale if the product covering includes a mark of inspection and established number.
Be aware that the FSIS regulates products that contain 2% or more cooked meat or poultry meat and 3% or more raw meat or poultry meat. The FDA regulates “meat flavored” sauces and soups with less than 2% meat or poultry meat.
There are various forms of branding for products in the U.S.:
- U.S. Inspected & Passed Brand
- Minimum of one required on each separate piece (side, quarter, primal part, etc.)
- Size and/or shape identify species
- U.S. Inspected & Condemned Brand
- Applied to carcasses and parts that have been inspected and found to be adulterated and condemned under the regulations
- U.S. Passed for Cooking Brand
There are also terms for marking and carcass misbranding. Marking refers to the application of lettering or affixing of tags directly onto a product. Branding is a form of marking. Carcass misbranding occurs when a mark of inspection is applied to uninspected adulterated or unwholesome carcasses or if a mark of inspection for one species of livestock is applied to another species. Be aware of these applications and avoid these mistakes.
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