Tip of the Week - Sorting Out the Details of Dual Label Formatting

If you have particularly complex labeling questions, which most of our customers do, then you will probably find yourself sorting through the FDA regulations clutter.

That's where AIB International's webinar, Making the Transition to FDA's New Nutrition Facts Label comes in. Our hour-long webinar explains the new format in much more detail. FDA regulations can be messy so this week's support tip will discuss the new label changes for a dual format and the requirements for its use.

Q.  I make a food where each piece weighs between 200 and 300 percent of the reference amount customarily consumed (RACC). Each piece may be sold as a single unit in a package or there may be multiple units in a package. I’m confused when I'm required to use the dual label format.

A.  Due to its weight, this type of food will always need the dual label format showing nutrition per serving derived from the RACC amount and showing nutrition for the entire unit. Let’s say that you are selling a muffin packaged individually that weighs 250 grams. The RACC for muffins is 110 grams. This means that the package for the single unit is just over 227% of the RACC. You would need to include a nutrition panel that shows the nutrition per ½ muffin (the serving size derived from the RACC) and also shows the nutrition per the entire package. If this same 250 gram muffin is sold in a package of four muffins, the nutrition panel would again need to show the nutrition per ½ muffin and also show the nutrition per 1 muffin. 

As a different example, let’s use mini muffins where each piece weighs only 40g. When you have a package of mini muffins that falls between the 200 – 300% of the RACC, you still have to include a dual nutrition panel showing the nutrition for the serving derived from the RACC and the nutrition for the entire package. If a package has 6 mini muffins, this would be 240 grams, which is 218% of the 110g RACC. The serving size derived from the RACC would be 3 muffins with a weight of 120 grams. So you would use a dual format with the nutrition for 3 muffins (120g) and a second column for 1 package (240g). However, if these same mini muffins are sold in a package that weighs over 300% of the RACC, e.g. 10 mini muffins weighing 400 grams, the nutrition panel only has to reflect the nutrition for the serving size derived from the RACC or 3 muffins (120g).

Keep the knowledge flowing! Our experts in AIB's FDA-sanctioned nutrition program are well versed in the new regulatory requirements and are sharing their knowledge.

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