One of my clients needed some nutritional info generated for a product that was slightly changing – a new sku with the same ingredients and recipe of an existing item, but made into a different form factor and package size. They sent me a mock up label to review and when I printed it at the proper size, some of the nutritional info was so small it wasn’t clear/legible. The graphic artist just took the old nutrition panel and scaled it down to fit, not taking into consideration any FDA guidelines – they probably never dealt with this before. The good thing was that my client knew that something wasn’t quite right and knew to ask me for guidance. It’s still a work in progress, but at least the project is on the right track.

Usually I wouldn’t write about this, but in the last few weeks I’ve seen other examples like this out in the wild…

Sometimes I can be easily influenced by things I see on the internet, especially when it comes to food. If I see a video about a juicy burger or maybe a recipe for some yummy looking chocolate chip cookies that includes freeze dried raspberries, I end up thnking about that for several days.

One night I was scrolling thru The Gram and saw something about a hot sauce made with white habaneros. I had no idea there were white habaneros. (I might have to try to grow these now.) As I investigated more, I saw that this sauce was being sold at a butcher shop that I knew of here in SoCal (I’m not naming the sauce or the shop as my purpose here isn’t to be calling them out) and the next time I was in that area, I made a side trip to try and find it.

I secured a bottle and as I looked closely at the label, I noticed a few things that didn’t look quite “in spec” for a consumer packaged good (CPG).. some of the print was very small and the company info was sparce(missing).

For some backstory, many years ago when I was involved in starting up a hot sauce brand, we had the label artwork done by a graphic artist recommended by the co-packer, which we used for several years. As we grew and needed to move to a larger packing facility, the new production facility kicked back the artwork saying it didn’t pass the FDA Guidelines. Come to find out, all those years, Xanthan Gum was spelled wrong (Xantham) and that one letter was enough, that it could’ve gotten us into trouble. Enough so that this larger packing facility wouldn’t start working on the sauce until we fixed any/all issues. This is what got me to really dig into and understand the FDA requirements for product labeling (now some consider me an expert).

This shows how some places will not be so strict and some will follow every tiny detail. Generally smaller places (brands, manufacturers, and retailers) might be a little looser than bigger places, maybe because they have more on the line if there is an issue.

When we dealt with some major nationwide healthy/gourmet grocers, they would require 3rd party audits of everything involved in producing a product – double checking everything, so that they weren’t on the hook. And take note if you want to be Certified Organic, that is a whole other set of details you need to adhere to.

I learned a lot about what is proper in labeling food products. The FDA publishes guidelines which include where elements, like Nutrition Facts or Ingredient List, should be placed and also graphical specs like font style and size.

I heard that a big box store was carrying some small producer coffee beans. I got excited when I saw one roaster I knew of from Las Vegas and there was another I hadn’t heard of before. When looking at that bag, it had the brand name but no other information like city, state, zip which is a minimum req in my mind, only a web address. The FDA guideline is, if the company can be looked up in a phone directory so they can be contacted then street and phone is not needed. (Maybe the FDA needs to update this to cover more modern communication methods, but I think actual direct contact info is needed not just a webform to send an inquiry, but a way to contact if there is an urgent allergy or illness related issue.) I was very surprised to see this in a major retailer, but wondered if coffee had different guidelines and apparently it does.

So anyway, all of this to say, if you are wanting to start selling a food product, do your homework. Make sure you know what is required or at least know enough to find people to help you. People who know what to look for and what questions to ask. A lot of things you wont even know if there is a question that needs to be asked. Maybe I’ll do another post about net quantity statements and departments of weights and measures.

Stay cool. Mahalo 🤙

-john.

links:

Raspberry Choco Cookies: https://healthynibblesandbits.com/raspberry-chocolate-oatmeal-cookies/
White Habaneros: https://pepperscale.com/peruvian-white-habanero/
Coffee bean label info:  https://www.inkablelabel.com/ultimate-guide-to-custom-coffee-labels
My go to starting point is usually this FDA Guidance for Industry: Food Labeling Guide (pdf link):
https://www.fda.gov/files/food/published/Food-Labeling-Guide-%28PDF%29.pdf

Nutrition Facts specs