Our company prints some of our labels in house. We are a RTE sandwich producer. There have been many instances of mislabeling and some customers have received wrong product due to this issue. I am new to the company and at my previous place our labels were serialized so that we could account for labels returned without physically counting labels on the roll that were left over.
My previous employer however produced for further processing.
My question is: If we serialize labels here and I am talking about just a small box on the corner of the label with a number, do we have to resubmit our labels for approval to USDA and FDA?
The label checks they already have in place are obviously not effective, because they continue to have issues so I feel like accounting for the labels and having them checked in after a changeover would prevent this.
Thank you in advance for your assistance!