September 22, 2023

Do All Product Ingredients Need To Be Declared On Food Labels?

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You might have wondered if small amounts of an ingredient can be added to a food product without being declared on the food’s label. The FDA requires that all ingredients added to food must be disclosed on the food label’s Ingredient Statement. Ingredients that are more than two percent of the product’s total must be listed by weight in descending order, followed by ingredients that weigh in at “2% or less” of the total—written in any order.

Not required on the Ingredient Statement are incidental additives and processing aids that have “no functional or technical effect in the finished product.” This includes trace amounts of food unintentionally added by farming practices or manufacturing equipment, including allergens.

Advisory statements on labels about the possible presence of trace allergens (“May contain wheat”) are voluntary.

What Additives Are Required To Be On Food Labels?

Food labels must declare all ingredients that serve as chemical preservatives, listed by their name and function, i.e., potassium sorbate (to preserve freshness). If a chemical preservative is present in one of the product’s ingredients but made inert (no longer functioning as a preservative) during processing, it does not need to be on the label.

Should you worry about allergens or gluten when you see the word “spices” on a food label?

Products containing spice blends with added ingredients (e.g., sugar, salt, a carrier such as wheat) must list the added ingredients separately on the label and follow FDA allergen labeling requirements. Gluten is not a concern with added spices since by definition, spices are gluten-free.

When a Product Is Labeled “Natural,” What Does That Mean?

FDA regulations state that products claiming to be “natural” cannot contain added colors (from any source), artificial flavors, or chemical preservatives.

Label Regulations for Farmer’s Markets or Online Products

All foods sold in the U.S., including from farmer’s markets or the Internet, must comply with FDA food labeling regulations. The regulations state that all food labels must declare five things:

  1. Product identity
  2. Net contents
  3. Ingredients and allergens
  4. Nutrition facts
  5. The company’s name and address.

Small businesses (grossing less than a certain amount annually) can be exempt from nutrition facts labeling but are still required to comply with the other four label components, including ingredients and allergen listing.

However, if a small business makes a health or nutrition claim on their packaging (e.g., low fat, high in protein) nutrition information must appear on their label.

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