What Does the FDA Say About Food Labeling Practices?

While the FDA can add new allergens to their guidance for labeling, a manufacturer can still petition to have their food ingredient removed from the list. However, this only applies if there is scientific evidence demonstrating that the food ingredient will not cause an allergic reaction that can pose a risk to human health. In other words, if there is proof that a named allergen will not put a consumer at risk, it is possible to have it removed from the list of allergens. This enables manufacturers to provide valuable input to the guidelines, while also making sure that allergens which do carry a significant health risk are properly labeled. If a new allergen is added or removed, a new version of a product label will need to be produced. These kinds of changes are one reason why many manufacturers use vision inspection systems to verify that the correct version of a label is present. 

For plant-based alternatives, the new guidance is primarily concerned with "truth in labeling content". Manufacturers are eager to advertise their plant-based alternatives in ways that are appealing to the consumer. A manufacturer may prefer to call their product a "Vegan Burger" rather than a "Soy-based Vegan Burger," but to adhere to truth in labeling practices, they must go with the latter. However, because a lot of the compounds and combinations of plant-derived materials don’t have standard names, it makes accurate naming more challenging. How much of a patty needs to be derived from soybeans to call it a soybean patty? That is the sort of question this guidance is meant to address.

The primary goal is to inform consumers of the ingredients that are in the food they’re buying. For most foods, this requires manufacturers to use what the FDA refers to as "common" or "usual" names. Unfortunately, many plant-based alternatives do not have common names in the same way as other foods. The FDA's draft guidance does not currently plan to establish common names for plant-based alternatives, requiring instead the addition of a "statement of identity." This statement informs the consumer of the specific plant sources that make up the ingredients of the product. For example, a yogurt alternative needs to state clearly if it is soy-based or almond-based. If the statements are unclear or misleading, the manufacturer can be subject to fines.

All the knowledge in the world is useless if you end up putting the wrong label on your product. Labeling errors, particularly labels with missing or inaccurate text, are a major cause of product recalls. The FDA does not give specific requirements for how labels should be inspected, but they do suggest automating inspection, which can reduce human error to increase consumer safety. As with other types of product inspection, full automation of vision inspection allows for the inspection of every product on the line. This is more effective and accurate compared to manual spot checking or random sampling. Automated vision inspection systems are a cost-effective solution to identifying mislabeled products and spotting missing information due to label defects. They can also be combined with other product inspection systems to further enhance product quality and save space on a production line.