- Why Trustwell
There are many reasons why clear ingredient statements and allergen declarations are important. For one, consumers want to know what is contained in the food they’re consuming. Creating clear ingredient statements can help establish trust with your customer base and protect their health and wellbeing if they have severe food allergies. Without allergen declarations and ingredient statements, consumers could accidentally ingest an allergen, resulting in severe illness, hospitalization, or death.
For this reason, the Food and Drug Administration (FDA) establishes clear regulatory expectations for food companies to standardized Nutrition Facts labels, ingredient statements, allergen declarations, and other packaging claims and product information when creating packaged food products intended for sale in the U.S. If food companies are found in non-compliance with these regulations, they could face a costly recall due to consumer safety risks and other legal ramifications if consumers incur illness or death due to mislabeled products.
In our recent blog series, we’ve covered how Genesis Foods can help companies accelerate accurate nutrient calculations, launch new food products, and help companies maintain compliance with ever-changing regulations. In this blog, we’ll cover how Genesis Foods built-in compliance tools can simplify the complexity of creating accurate ingredient statements and aligning with government regulations on allergen declarations. Let’s dive in.
Ingredient Statement Requirements
Ingredient statements may seem pretty cut-and-dry. But, unlike your favorite recipe to make at home, ingredient statements have some important distinctions on how they should appear on a food label. According to FDA guidelines:
- Order: Ingredients must be listed in descending order of predominance (by weight, not volume).
- Common Names: Ingredients should be listed using their common names – such as listing “sugar” and not “sucrose.” There are some exceptions for color additives, spices, and incidental ingredients (see 21 CFR 101.22 (k)(1)).
- Packaging Position: The ingredient list can appear before or after the Nutrition Facts panel but should be on the same label panel as the name and contact information of the manufacturer. (See our Product Packaging 101 blog post or our Food Labeling eBook to learn more.)
- Format: The type size should be prominent, easy to read, and at least 1/16th of an inch in height.
- Sub-Ingredients: When a recipe includes sub-ingredients, the sub-ingredients can be listed in one of two ways, either listed parenthetically following the parent ingredient, or dispersed throughout the Ingredient Statement in the proper order of predominance by weight. [Example: if listing sub-ingredients as a parenthetical: “Tomato puree (water, tomato, salt)”, or listing by weight: “water, tomato, salt, etc.…”]
FDA guidelines include other specifications for the ingredient list, such as how to label spices, trace ingredient amounts (and using “Contains less than 2% of”), and more. Just like Nutrition Facts labels, the FDA has created strict rules for food manufacturers to follow so consumers can make educated dietary decisions.
Interestingly, though, the FDA allows some exemptions for small businesses when it comes to creating and displaying Nutrition Facts labels on their food packages. However, small businesses are not exempt from displaying the ingredient statement for their packaged food items.
How Genesis Helps with Ingredient Statements
Genesis Foods is pre-built with the government guardrails needed to help food companies align with government regulations when creating Nutrition Fact panels and ingredient statements. So while it may seem overwhelming to read through the entire FDA Food Labeling Guide, the process is a lot easier with Genesis Foods.
As you input your recipe and the system generates a Nutrition Facts label, the ingredient list will also populate and automatically order itself based on the weight of ingredients in the recipe. The system will size the font appropriately, and you can toggle between parenthetical sub-ingredients, or list everything in order of weight. You can further customize the label with alternate ingredient names and a bilingual translation.
Allergen Declaration Requirements
Food allergens pose major health risks for consumers with severe food allergies, and as such the FDA enacted the Food Allergen Labeling and Consumer Protection Act (FALCPA) of 2004, which went into effect in 2006. According to the FDA, 160 foods have been identified as causing food allergies, but the nine major food allergens that must be declared make up about 90% of all food allergy cases in the U.S. Those major allergens include:
- Crustacean Shellfish*
- Tree nuts*
- Sesame (added in 2023)
*Must identify the species (e.g., for “tree nuts” you must indicate if it’s pecans, almonds, walnuts, etc.)
Food manufacturers must include the species-specific common name of any seafood (fish and shellfish) and tree nuts when listing allergens. To learn more about the specific species – as well as common synonyms that might be hiding in allergens – check out our Allergen Synonyms, Species, and Types blog post.
FALCPA labeling requirements apply to any food that includes any of the nine major allergens as an ingredient (including flavoring, coloring, or trace amounts used for processing). Additionally, there are two ways to list allergens that comply with FALCPA regulations. You can either:
- Clearly identify the allergen or allergens within the ingredient statement. This can be achieved if the common name of the ingredient itself is the allergen or by use of parenthetical listing the allergen immediately following the common name of the ingredient. [ex: Peanut butter (peanuts), casein (milk), spice mix (sesame)…]
- Or list the allergen in a separate “Contains” statement under the ingredient statement. [ex: Contains: peanuts, milk, and sesame]
How Genesis Helps with Allergen Declarations
Genesis Foods offers a variety of compliance checks, and our allergen declaration check is unique and potentially one of the most beneficial features of the system. Across the U.S., one of the leading causes of major food product recalls are undeclared allergens or mislabeled allergens. While recalls of any kind can damage consumer trust, undeclared allergens are considered a significant food hazard that can lead to serious illness or death. Missed allergens can easily turn into a much bigger problem for food manufacturers and consumers.
For those reasons, Genesis Foods automatically assigns all allergens to ingredients in the system to avoid missing this essential step. Recipe developers and compliance experts can then review the recipe or ingredient and remove any allergens that are not present in the formula.
Companies can add custom names for required allergens, such as a species-specific tree nut (ex: pecans, almonds, walnuts), or any “may contain” allergen warning statements. The system will also show you automatically how the allergen statement will appear on the label, including options to add bilingual translations. To see how easy it is, watch our Allergen Statement Tutorial.
Maintain Compliance and Accuracy with Genesis Foods by Trustwell
For the sake of consumers and your business, it’s important you get food labeling right from the start. With solutions like Genesis Foods from Trustwell, you can label your products with confidence, align with government regulations, and create clear, accurate ingredient and allergen statements in a matter of minutes.