How Food Importers Can Comply With FDA Ingredient Labeling Requirements

Food products imported into the United States must have an ingredients statement declaring all ingredients contained in the product. But it’s not as simple as a mere declaration. FDA regulations require that ingredients be listed in a certain order, named in the correct manner, and placed on a specific location on the packaging. Therefore, it is not a given that you can simply use the product’s existing ingredient list. You must review the ingredient statement for FDA compliance.

Complying with U.S. labeling requirements is not just a matter of common sense, nor is compliance something that can be done after your import deal is inked. As you will see below, FDA regulations require a meticulous examination of every ingredient to determine the proper placement, nomenclature and other ingredient statement requirements.  

Failing to comply can be very costly. Ingredient errors and omissions are one of the top reasons for food being denied entry into the United States. Inaccurate ingredient statements have also led to import detentions, consumer lawsuits, and lawsuits for failure to disclose food allergens on labels. Ingredient statement compliance is extremely important and should be taken into consideration before importing a food product into the U.S. 

The following are a general list of ingredient labeling requirements:

• Ingredients must be listed on the same panel as the manufacturer’s information.
• Ingredients must be listed in a type at least 1/16” tall and be easy to read.
• Ingredients must be listed in order of predominance; the ingredient with the greatest mass is listed first and then the rest of the ingredients are listed in descending order by mass.  
• Ingredients must have their common or usual name unless a specific regulation requires use of a different name. An example of a common or usual term of an ingredient is “sugar,” instead of the scientific term “sucrose”.
• Spices, natural flavors and artificial flavors are declared using specific common or usual names such as “spices”, “artificial flavors”, or “natural flavors.” There are nuances to this rule, however, so be sure to check the proper regulations for labeling spice ingredients. 
• Sub-ingredients may be declared in parentheses following the name of the ingredient or they may be declared by breaking down each ingredient in order of predominance in the ingredient list itself.
• “Trace” or “incidental” amounts of products need not be declared unless they are a major food allergen.
• Ingredients that are the source of specific allergens must be declared in a specific manner.
• Chemical preservatives must include both the common or usual name and the function of the preservative (e.g., “to retard spoilage” or “a mold inhibitor.”)

Aside from these general rules, there are many nuances to the ingredient statement rules that can result in non-compliance. For example, water may or may not be required as an ingredient, depending on how it was used during product manufacturing.  

U.S. Imports can review your ingredient list to help ensure smooth sailing of your imported food product. For more information click here.