Writing an accurate ingredient statement for packaged food products
Helpful tips from the Michigan State University Product Center.
Michigan State University Extension’s Product Center provides business counseling and specialized services for Michigan-based food, farming, and beverage businesses. All packaged food products, including those sold under Michigan’s Cottage Food Law, must list an accurate ingredient list on the label. The following are some helpful tips for creating an accurate ingredient list for food and beverage business owners.
Food and beverage labeling must meet the requirements set by the U.S. Food and Drug Administration (FDA), which regulates these products. The U.S. Department of Agriculture (USDA) regulates the labeling of meat and poultry products. A detailed FDA food and beverage labeling guide can be downloaded at this link. In addition, the Michigan Department of Agriculture and Rural Development has a shorter version of this guide available at this link. For information on USDA label requirements, visit this link.
A food and beverage product’s ingredient list must be listed in order of prominence. The easiest way to list ingredients correctly is to convert the recipe to weights and list items in order of heaviest to lightest. For example, if I were making chocolate chip cookies, my recipe may be as follows:
Example Chocolate Chip Cookie Recipe
(Note this is not a real recipe for production, just an example)
|Light brown sugar
|Egg (1 large)
|Pure Vanilla Extract
The recipe above is listed in order by weight with the heaviest item listed first. Your ingredient list on your label will be in this same order. In addition to the ingredients being listed by weight, sub-ingredients must be listed in parenthesis beside the ingredient. Sub-ingredients are the ingredients of each ingredient. Sub-ingredients are listed so consumers can see if any of these items may cause them harm. For example, garlic is not a top allergen and will not be identified in an allergen statement, but some people are allergic or sensitive to garlic, which is a common ingredient and sub-ingredient.
To find the sub-ingredients, look at the package of each ingredient used and read the ingredient list. All-purpose flour may have these sub-ingredients: enriched, unbleached wheat flour, malted barley flour, niacin, iron, thiamin mononitrate, riboflavin, and folic acid. Similarly, chocolate morsels may have these ingredients: sugar, chocolate, milk fat, cocoa butter, and soy lecithin. Some ingredients do not have any sub-ingredients. Salt typically does not have any sub-ingredients.
An example of a final ingredient statement for the chocolate chip cookie recipe above is:
Ingredients: All-purpose flour (enriched, unbleached wheat flour, malted barley flour, niacin, iron, thiamin mononitrate, riboflavin, folic acid), chocolate morsels (sugar, chocolate, milk fat, cocoa butter, soy lecithin), light brown sugar (sugar, cane molasses), granulated sugar, egg, butter (pasteurized cream), baking soda, pure vanilla extract (water, alcohol, vanilla), salt.
In addition to the ingredient list, the top nine allergens must be identified on your label. There are two options for listing allergens: 1) in parentheses following the name of the ingredient (i.e., lecithin (soy) or flour (wheat)) and 2) immediately after or next to the list of ingredients in a “contains” statement (i.e., Contains wheat, milk, and soy). To read more about allergen requirements on your label, visit this link. The top nine allergens are milk, eggs, soy, wheat, peanuts, tree nuts, fish, shellfish, and sesame.
If you are making your product in a shared kitchen, many food inspectors will ask that you add a shared kitchen statement to your label below the allergen statement. This statement will list all allergens that are allowed in the shared kitchen. For example, “Made in a shared kitchen that also processes soy, wheat, peanuts, tree nuts, and sesame.” If you listed an item as an allergen in your product, you do not need to list it again in the shared kitchen statement because consumers know it is already contained in your product.
Ingredient statements and allergens are very important. If you change ingredients, you must change your label. If you do not declare an allergen, you must recall the product, which can cause significant time and money.
One of the most common questions from food and beverage business owners to the MSU Product Center is, “Are Nutrition Facts Labels required for my products?” For non-meat products, the FDA allows for a small business exemption for Nutrition Facts Labeling. This exemption applies to retailers with annual gross sales of no more than $500,000, or with annual gross sales of foods to consumers of not more than $50,000. This exemption does not need to be filed with the FDA. Foods and beverages that make a health claim such as “low in fat” or “high in fiber” must have a Nutrition Facts Label. For more information on the small business Nutrition Facts Labeling exemptions, visit this link.
However, it should be noted that many grocery stores and other retailers will require Nutrition Fact Labeling to sell products in their stores. Be sure to connect with store buyers in the locations where you want your products sold to see if Nutrition Facts Labeling is required.
Connecting with your MSU Product Center counselor
The Michigan State University Product Center is a resource for Michigan-based packaged food and beverage manufacturers to develop business plans and understand licensing and regulatory steps for launching food and beverage products. In addition, the MSU Product Center provides Nutrition Facts Labeling as a fee-based service. Food and beverage manufacturers can request counseling and Nutrition Facts Labeling from the MSU Product Center through the “Become a Client” link on the website at canr.msu.edu/productcenter. There is a $100 application fee to join.