Peel Out Labels

My company is reviewing peel-out labels for dietary supplements packaged in bottles.  The current proposal is to have the supplement facts completely on the inside of the peel-out label, not on the front at all.  From what I can tell in reading the regs, the supplement facts should at least start on the information panel (directly to the right of the principle display panel).  Am I on the right track?  Does anyone else think that the supplement facts may be allowed to NOT be on the information panel and can be completely printed on the inside?

Thanks,

Scott

May I locate the "Supplement Facts" panel on other than the information panel?Yes. If there is insufficient space for the "Supplement Facts" panel on the information panel or the principal display panel, you may locate it on other panels that can readily be seen by consumers in accordance with 21 CFR 101.9(j)(17).

I guess having it inside makes it still readily seen by the consumers, especially if you put an arrow indicating it being there. I have seen other bottles have that before. Let's see what everyone's thoughts are on this.