Hello,
Currently we have some packaging that we are working through that meets 2019 FDA Packaging regulations. I know that there have been some updates to the 2020 regulations which we have addressed in our new packaging.
The question I have is this...we have a product that is RTE wrapped in the 2019 packaging but the bulk packaging is the 2020 packaging with the required changes. could this present a problem with FDA?
our justification for this is that we are not intentionally printing old packaging but just working through we currently have on hand. and will make the necessary changes when we re order.
any information with regulatory evidence would be much appreciated.
THANKS!
If you're talking about labels on the packaging - no this is not allowed. However I do believe they extended the time for small businesses to be in compliance.
https://www.fda.gov/...ion-facts-label
https://www.fda.gov/...ion-facts-label
When will I start to see the new label?
Many manufacturers are already using the new label, but they have more time to make the changes. Changes must be made by January 1, 2020, for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food sales have an extra year to comply – until January 1, 2021. Manufacturers of most single-ingredient sugars such as honey and maple syrup and certain cranberry products have until July 1, 2021 to make the changes. Manufacturers of certain flavored dried cranberries have until July 1, 2020 to make the changes.
14. How much time will manufacturers have to make these changes?
The FDA extended the compliance dates for the Nutrition Facts and Supplement Facts label final rule and the Serving Size final rule, from July 26, 2018 to January 1, 2020, for manufacturers with $10 million or more in annual food sales. Manufacturers with less than $10 million in annual food sales would receive an extra year to comply – until January 1, 2021. Manufacturers of single-ingredient sugars such as honey and maple syrup and certain cranberry products have until July 1, 2021 to make the changes.