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labels Ingredients Label

Hello All.

First time poster. Big time fan.

I'm working to launch a sauce business and have many questions. One question I have not been able to find an answer to is around the protocals/requirements of listing my ingredients on my labels. I know there is a small business exemption possible, but I have every intention of putting ingredients list on my label. So I'm struggling with a couple of things.

1. I have a key spice ingredient that I'd prefer not to list. What are rules around just listing "spices?" I see many food products that simply list "spices". If I prefer not to disclose my key ingredient, can I just lump it into "spices?"

2. Ketchup is one of my ingredients. While I could make my own ketchup, it's much easier to just use canned ketchup and it does not add significantly to my per ounce cost. But I feel that listing "ketchup" is not super classy. If I were to just list the components of the precanned ketchup how would I know what order to list those components in relation to the rest of my ingredients? Any one have experience with this?

Many thanks.
 

HellfireFarm

Business Member
I've been going through the exact same thing recently. I'm sure you know the requirement to list in descending order by weight. That makes it difficult to know how to list the ketchup ingredients without just listing "KETCHUP (TOMATO PASTE, VINEGAR, ...)" at the appropriate place. I think without knowing the actual quantities in the source product, you would just be guessing. I don't know that listing it would be bad - I see a lot of sauces out there with "ketchup" on the label.

Or maybe make your own? :)

For spices, maybe this will help?

And if you haven't seen it already, I have this one bookmarked: https://www.fda.gov/media/81606/download - it's a really good reference.

FDA labeling exemption appears to only apply to nutrition labeling: https://www.fdareader.com/blog/2018/12/11/exemption-from-food-labeling-requirements
 
I've been going through the exact same thing recently. I'm sure you know the requirement to list in descending order by weight. That makes it difficult to know how to list the ketchup ingredients without just listing "KETCHUP (TOMATO PASTE, VINEGAR, ...)" at the appropriate place. I think without knowing the actual quantities in the source product, you would just be guessing. I don't know that listing it would be bad - I see a lot of sauces out there with "ketchup" on the label.

Or maybe make your own? :)

For spices, maybe this will help?

And if you haven't seen it already, I have this one bookmarked: https://www.fda.gov/media/81606/download - it's a really good reference.

FDA labeling exemption appears to only apply to nutrition labeling: https://www.fdareader.com/blog/2018/12/11/exemption-from-food-labeling-requirements

Thanks Hellfire this is really helpful. I had not seen that one about the spices. For the ketchup I have thought about making my own but it's so much easier to use pre-made lol
 

HellfireFarm

Business Member
Thanks Hellfire this is really helpful. I had not seen that one about the spices. For the ketchup I have thought about making my own but it's so much easier to use pre-made lol
Getting the mix right is the hard part, after that you don't even need to "make ketchup" first - just throw it all in together! At least, that's what I do :)
 

salsalady

Business Member
You would probably have to get your licensing entity to sign off on what can be included in the Spices listing.

If using any premade product like Worchestershitshire or ketchup, it needs to be listed by name and all the ingredients listed in parentheses exactly as listed on the original product label.

Good luck and Have Fun!
SL
 
Thanks SL. Which licensing entity are you thinking of and at what point would they sign off on my ingredients label?

I've just gotten in contact with a company called LabelCalc. They said their database includes all major brand name ketchup and their software would generate a label with the components of that ketchup automatically ordered in relation to my ingredients. Supposed to be FDA compliant.

Do you have any experience with LabelCalc?
 

salsalady

Business Member
What area of Warshington are you at? I am in the Methow Valley, north central...just wondering...


I am not familiar with that company. Hold off on anything for making labels until you have your recipe dialed in, approved, licensed.

As to licensing, where are you thinking of selling? Local only, internet?
 

salsalady

Business Member
 

WarrantMan

Extreme Member
Great advice from salsalady. Do take heed.

From the entities in my state (SC) the Dept. of Agriculture, working in tandem with the FDA, now makes it mandatory to include (parenthetically) even the breakdown of my vinegars on the labels. eg. Apple cider vinegar (apple cider vinegar, diluted with water to 5% acidity). Didn't see this one coming. Luckily, a light "grandfathering" exception exists ... otherwise it would be a loss of thousands $

Absolutely do your homework before you commit to the expense of labels.
 

salsalady

Business Member
Yep... what WM^^^...said. in some markets, the label can be disapproved if the Font isnt the correct size....


Label printing= one of the last things to do on the hot sauce journey...
 
Thanks again SL! I'm on the Eastside of Seattle in Redmond.

To start I plan on selling online. I have talked to a copacker in Tacoma that I think might be a good fit. (Low minimum run of 40lbs). But we have not gotten into specifics.

A few questions I have regarding a copacker are: Would I need a food processors license if I go with a copacker? Food processors insurance if I use a copacker? Would I need to attend a BPC school if I go with a copacker?

I've got an LLC setup and have my State/City business licenses.

I know I still need to get my recipe tested by a process authority and that is my next step once I nail down my own mix of ketchup. I tested acidity with a Hanna meter and got a reading of 3.8 so thinking I'll need a HFH method.

Edit: I still don't understand who is approving my ingredients and nutrition label? I should qualify for the small business exemption on nutrition labels but I have not seen anything that specifically mentions an inspection of my ingredients label. When does that step occur?
 
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salsalady

Business Member
If using a copacker, their licensing should cover all processing. You show up, load the cases in your vehicle and off you go. You should have business insurance for selling a food product. If using a copacker, it is a bit nebulous who would approve the label. I would see if the process authority would do the ingredients listing review in conjunction with the recipe review. Ingredients are listed in descending order. Pick a unit, weight or volume, and use that for all ingredients.

Beyond that, i would suggest doing some label short runs for the first few. You may decide to use a premade catsup after a few batches, or maybe you find frozen tomato puree instead of tinned puree with preservatives.

Have Fun!
SL

Edit- when submitting your recipe for review, have all ingredients in the same unit. By weight is the best. Not 1 cup catsup, 4 oz onion, 1 tsp salt...
250 grams catsup, 125 grams onion, 8 grams salt...

This also makes it easy to list in descending order.
SL
 
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salsalady

Business Member
I use university nebraska Lincoln with very positive experiences.
Services listed include labeling compliance.

Others have reported good experiences with Cornell Univ back east.

I tried using WSU 15+ years ago and had terrible experiences...(plural). With a new director of the food science dept, maybe its better???

You do not have to use a Washington based PA. Any licensed University food science dept or independant lab will work. Univ FS programs are good about working with new processors. I have seen UNL and Cornell work with a number of fledgling processors/sauce developers.
 
I use university nebraska Lincoln with very positive experiences.
Services listed include labeling compliance.

Others have reported good experiences with Cornell Univ back east.

I tried using WSU 15+ years ago and had terrible experiences...(plural). With a new director of the food science dept, maybe its better???

You do not have to use a Washington based PA. Any licensed University food science dept or independant lab will work. Univ FS programs are good about working with new processors. I have seen UNL and Cornell work with a number of fledgling processors/sauce developers.

That's very interesting. Should have guessed Wazzu would Coug it up. Thanks!
 
Hey SL, do process authorities typically provide a nondisclosure agreement? I thought that would be pretty standard but the person I spoke with at UNL said they wouldn't provide NDA.
 

HellfireFarm

Business Member
Edit: I still don't understand who is approving my ingredients and nutrition label? I should qualify for the small business exemption on nutrition labels but I have not seen anything that specifically mentions an inspection of my ingredients label. When does that step occur?
I think it's a bit nebulous and varies by state. In NC, from everything I've been able to find out from the Dept. of Agriculture, apparently they don't pre-approve labels, they only enforce upon complaint. No idea how it is in your state.
 

WarrantMan

Extreme Member
Interesting. I naively believed it was more uniform across the states. Apparently not.

I started my biz with a co-packer. (as SL mentioned) they did the work of submitting my sauces for the process letters. I was clueless in the beginning and have learned much along the way. Yes, there are parameters where a nutrition panel is legally required. Off the cuff from recollection, it has to do primarily with volume of sales. I opted to have a nutrition panel voluntarily, not because it was required in my case, but simply because I thought people expected it. Again, as I mentioned in the post above, the "authority" who approved my labels was the SC Dept of Agriculture. This issue was mine alone, disconnected with the co-packer. My recipes and production processes were sanctioned by the "process authority" who produced the letters (in my case) half were done by NC State University and the others by Clemson University. The co-packer is already "approved" for production. But final approval with labels were with the dept. of Agriculture. As far as a non-disclosure agreement, I have one with the co-packer, but no such language existed with the process/testing authorities. I don't really see that as an issue of concern.

Here where I am, and perhaps where you are as well, it may be similar. You go with the co-packer, they submit your stuff (to whatever process authority) and get the "process letters." They are good for production, however, the labeling may or may not be part of your co-packer arrangement. If it is, design your labels and let them go to work for you.

In my case it was not. My co-packer would "apply" the labels to the bottles as figured in on cost, but getting them "approved" fell on me. I discovered it was not easy. Our dept. of Agriculture administers and governs these things for the FDA. As Salsalady pointed out, even the "fonts" are regulated. What info goes where on the label are also regulated (left, right, top, bottom etc..) The size of each element of the label is also regulated. It took me three times in the beginning to get my labels approved where I was legal to sell.. All was well for several years, until the Federal Government (FDA) revised requirements for the nutrition panel. Because I had them, I had to revise them for compliance. Just so happened, that my co-packer sold out to another around the same time. I had to do it ALL over again. This time, I got all process letters from Clemson University with the "new" nutrition panels included at no extra cost. A really lucky break for me.

Here following is a link that may assist you in your journey. Not all inclusive, maybe different where you are, but perhaps it may provide something of use .

Reggie

 
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