The United States and Canada have both made significant changes to their nutrition labels in the past year. In response, food manufacturers are dusting off each product’s Certificate of Analysis (COA) to create new nutrition labels in order to comply with updated regulations. But food manufacturers should consider how old their nutrient data is before using it to create a new label. Before sending those new labels to print, check to make sure your nutrient values are still usable. 

Reasons why a product’s nutrient data could have changed:

  • Ingredient Changes: When an ingredient, ingredient component or the source of an ingredient has changed, it’s advisable to verify the nutrient content.
  • Ingredient Variations: If an ingredient composition changes due to season, storage or other factors, then it could affect your data.
  • Processing Variations: If there’s a change in how a product has been processed, it’s time for a refresh.

Why is it Important to Keep Your Nutrient Values Accurate?
Food manufacturers will want to make sure everything listed on a label matches what is actually in their food product. The FDA has a set of guidelines to help companies ensure accuracy between declared and actual nutrient values. The FDA states in the Code of Federal Regulations (CFR), “The source of the data used to calculate nutrition label values is the prerogative of the manufacturer, but FDA’s policy recommends that the nutrient values for labeling be based on product composition, as determined by laboratory analysis of each nutrient.”

The FDA regulates Class I (Fortified) vs Class II (Naturally Occurring) in very different ways. For example, the analyzed values in Class II must be within 20% of the declared value. More specifically, desirable (“good”) nutrients such as vitamins and minerals must be greater than or equal to 80% of the declared value. Meanwhile, nutrients such as fat cannot exceed declared value by more than 20%.

Refresh Nutrient Values Through Label Verification
Mérieux NutriSciences recommends food manufacturers complete label verification every two to three years to make sure their label is up-to-date. This time period can vary depending on the food product. Some companies may also choose to test specific nutrients more frequently if they are at a higher risk for change.

The FDA’s regulations pertaining to verifying nutrient values on a nutrition label can be found in 21 CFR 101.9 (g). If the FDA decides to inspect a food company’s nutrient values for compliance, they would collect 12 samples of the product from 12 randomly selected shipping cases from the same code or lot. The lab would then create a composite sample from these 12 samples to be analytically tested using the method from the Official Method of Analysis of the AOAC International. The FDA will then compare the product’s Nutrition Facts Label to the COA. If the COA and the label for the product do not match, then the product is classified as misbranded. This can result in a fine, warning letter or a recall of the product.

The Canadian Food Inspection Agency (CFIA) has a compliance test to ensure the nutrient data on a label is correct per the Food and Drug Regulations. The CFIA’s first step is collecting three composite samples of four consumer units each from random lots. These composite samples are then analytically tested using the Official Method of Analysis of the AOAC International. The CFIA does offer alternatives to the number of samples they’re testing, which can be found on the CFIA website at the Nutrition Labelling Compliance Test page. The label and the COA are then reviewed to see if there are any discrepancies, which have similar consequences to those of the FDA.

The best practice for testing the values of nutrients is to collect 7 to 12 samples of a product during one production run. Each sample would need to be tested three times. This provides the food manufacturer with the average nutrient values. While this process is the “best practice,” it can be expensive and time consuming. However, there is a more cost-effective approach that still provides the food manufacturer with nutrient values they can trust. This approach requires manufacturers to collect three samples in one production run; preferably a sample from the beginning, middle and end. Each sample would then be analyzed by a third-party accredited laboratory to test for the nutrients the food manufacturer has requested. A food manufacturer may request analysis of all mandatory nutrients required for a fully compliant nutrition label or just a few of the nutrients. If the nutrient values are relatively similar, the food manufacturer may take the average. If the values are drastically different, a second test would be recommended.

Start Now
Food manufacturers need to begin the process of reviewing their product’s nutrient data soon, and to do so they need to verify that the nutrient values they have are accurate. If they need their values retested, then it can be completed through lab analysis or by calculated analysis, depending on the product and cooking method. The government of Canada has given the food industry five years to comply, and the FDA has given the food industry until July 2018 or July 2019 to comply with new regulations.

Do you need to verify your nutrient values on your nutrition labels? Our experts can help. Contact Mérieux NutriSciences today to complete Nutrition Labeling by Lab Analysis or Nutrition Labeling by Database and to learn more about our GAP Analysis Service for Nutrition Facts Labels.

Meet the Author

Sophie Plummer, RD
Associate Nutrition Program Manager, Mérieux NutriSciences

Sophie Plummer is the Associate Nutrition Program Manager at Mérieux NutriSciences. She received her Bachelor of Sciences in Applied Health Science, Dietetics from Indiana University. Sophie received her MBA from Dominican University. In her free time, she enjoys cooking for friends and family as well as playing with her goldendoodle.

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