New labels application

Hello everyone!

I think if you are an inspected warehouse you could do this in FDA-land. especially if the labels come from the vendor. More problematic if the food is canned or acidified maybe.

Under FDA rules there should be no regulatory reason why you could not apply new labels.  Just be aware that anyone who applies labels (whether they own the product or do it on behalf of another company) is responsible for ensuring that the labels are in compliance with applicable regulations.

Thank you for the responses!

Fishlady: Do you have any link to the regulation or guidance that explains with more detail what you mentioned? I want to discuss that topic at work, and it would be helpful to have some material to go over. 

Thanks!

Silvia

I am not finding the exact reference, but I have worked for companies that perform custom processing and/or apply labels that are designed by the customer, and I have been informed by FDA inspectors that if we apply the label, we are just as liable as the label owner.  I believe this may be related to the fact that FDA includes "labeling" in its definition of "processing" (see the definition of "manufacturing/processing" in 21 CFR 117.3).