Monday, February 27, 2006

Interpreting new label rules

New FDA labeling requirements for trans-fat and allergens take effect this year. Learn what bakeries need to do to comply with the law.

January 1 marked a new year. For food retailers, it also was the dawn of new labeling requirements. The Food and Drug Administration’s (FDA) new trans-fat and allergen labeling requirements went into effect at midnight, Jan. 1. Nutrition labels now require the amount of trans-fat be broken out from the total fat amount. And, products must also state if they contain one or more of the eight common allergens.

The effect on bakeries varies. If bakeries sell packaged products and sell more than $500,000, they need to have some sort of ingredient label on those products. However, products that are placed in packaging in response to a customer’s order do not require any nutrition information or allergen listing.

Understanding the requirements ensures your products are labeled accurately, and allows you to use labeling to your advantage.


The area of labeling receiving much attention is trans-fat with its many harmful effects. The impetus behind the attention is the official debut of trans-fat on nutrition labels in 2006.

Trans-fat is created when liquid oils are made into solid fat, a process called hydrogenation. A small amount of trans-fat occurs naturally, primarily in animal-based foods, such as dairy products. However, the primary source of trans-fat for bakers is shortening and margarine. These are staple ingredients for many sweetgoods.

Although the FDA brought trans-fat into spotlight, the administration is not suggesting people eliminate trans-fat completely from their diets. To do so would require consumers to make monumental shifts in eating habits. Bakers report that customer response to trans-fat initiatives has been low.More importantly for retail bakers, manufacturers producing ready-to-eat food on site are not required to have a nutritional fact panel. However, manufacturers that ship food to other locations must have nutrition facts labels on packaged products.

The nutrition facts label is the listing of serving size, calories, fat and other nutrients in the product. Under the new requirements, fat must now be listed with the total amount first, followed by the breakdowns of saturated fat and trans-fat. Sounds simple enough, but even this gets confusing.

Even if the product’s serving size contains no trans-fat, you must separate the fat and list the trans-fat as zero. However, if the serving contains 0.5 grams or less of trans-fat, the amount listed on the nutrition facts is zero, as long as no health claims are made. For example, if your cookie has 0.25 grams of trans-fat, you can list the amount as zero if your package does not contain a claim of low or no trans-fat.

If the product contains shortening or margarine, both sources of trans-fat that must be declared in the ingredient list, the product still can have the trans-fat listed as zero as long as the serving contains 0.5 grams or less.

If your product does not contain trans-fat, how can you let your customer know? That is still questionable. At present, the FDA has not established nutrient claims retailers can use regarding the amount of trans-fat.

While trans-fat is not being banned, the media attention on its harmful effects has prompted some food manufacturers to adjust their formulations to lower the amount of trans-fat in their products. Retail bakers, for the most part, say they are relying on their suppliers to provide trans-fat alternatives.

The reformulation will come from the suppliers changing the ingredients, not the bakers themselves making changes to their product.


Jan. 1, 2006 also required that products must clearly state if they contain any of the eight major allergens. Accounting for more than 90 percent of all documented allergic reactions, the eight allergens are: milk, eggs, fish (bass, flounder, cod, etc.), crustacean shell fish (crab, lobster, shrimp, etc.), tree nuts (almonds, pecans, walnuts, etc.), peanuts, wheat and soybeans.

The FDA estimates that two percent of adults and five percent of infants and young children in the United States are allergic to some type of food. About 30,000 people require emergency room treatment, and 150 die each year because of allergic reactions to food.

To indicate the presence of an allergen, manufacturers have two options. One, they may list the allergen in the ingredient list. All packaged products must contain an ingredient list, if the manufacturer reports more than $500,00 in sales.

For example, if the product contains enriched flour, the components of enriched flour, such as wheat flour, must be listed in parentheses after the ingredient. For ingredients that have several names, the most common name must be listed in parentheses. For example, whey (milk), or lecithin (soy).

The second option is to use the word “contains” followed by the name of the ingredient that is the major allergen. For example: Contains wheat, milk and soy. This statement must be immediately after or adjacent to the ingredient list and in a type size that is no smaller than that used for the ingredient list.

Bakers have long been aware of the dangers of food allergies, and even though there are no requirements to do so, many have already taken steps to let customers know the dangers people with food allergies may face when consuming bakery products.

Requirements may not apply to all bakeries, but knowing the rules are important as your bakery grows and you need to answer customers’ questions. Labeling also works as a marketing and promotional tool. Let your labels tell customers what they need to know.

Health claims and whole grains

Along with the FDA’s changes in labeling requirements, the USDA recently revised the U.S. Dietary Guidelines. The new recommendations suggest that at least half of Americans’ daily grain servings should come from whole grain foods, a minimum of three 1-oz. servings a day. This has raised consumer interest in whole grains.

To help bakers educate consumers about the amount of whole grains in their products, the Whole Grains Council created the Whole Grain Stamp.The stamp allows producers to designate their products as a good source of whole grains, excellent source of whole grains and 100 percent whole wheat.

Making sense of nutrition labels

While nutrition listings have changed, the standard label format has not. A nutrition facts panel, the breakdown of serving size, calories and fat, is required for all packaged products sold off site if bakery sales are more than $500,000 annually. A nutrition facts panel also is required if a health claim, such as low fat or sugar-free, is made on the package.

For packaged products, the part of the package that customers are likely to see first must feature the primary display label (PDP). It also should contain the net quantity or amount of the product.

The information panel needs to be positioned to the right of the PDP. The information panel should include the ingredient list, allergens, and the nutrition facts, if required.

The ingredient list should be in descending order by weight. Water is considered an ingredient. Enhanced ingredients must list their own ingredients in parenthesis. For example, if you use milk chocolate it must be listed as: milk chocolate (sugar, cocoa butter, unsweetened chocolate, whole milk powder, soy lecithin, vanilla). All spices must be listed separately, and if you use artificial colors or flavors, you must declare which ones. Finally, you must list all the allergens the product contains.The information panel also should include the company name, city, state and zip code. If your company is not listed in the phone directory, you must also include the street address. You may include phone and fax numbers and a web address.

For bakeries whose products must include a nutrition facts label, the label required depends on the amount of space on the package. If your label space is under 12 sq. ins., you must provide a phone number for customers to call for nutrition information. If the label is between 12 and 40 sq. ins., you can use the tabular or the linear forms. For labels over 40 sq. ins., you must use the long tabular form, which includes diet recommendations.

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