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Exemption from USDA and FDA Compliance for Labeling of Free Spice Powder Product

Started by Nalathu, Jun 01 2023 10:31 AM
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Nalathu

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Posted 01 June 2023 - 10:31 AM

Dear All,
 
I would like to seek your insights on a matter regarding the launch of a free giveaway spice powder product.
Our company is planning to distribute this product pack as a promotional item, and it will not be available for sale.
 
Given this unique circumstance, we are wondering if it is possible to exempt this product from
USDA and FDA compliance requirements specifically related to labeling.
 
I would greatly appreciate your expertise and input on this topic.
 
Thanks!

Scotty_SQF

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Posted 01 June 2023 - 11:09 AM

I would think you would still have to declare this on your label even though it is a promotional product.  A spice packet would set up alarms as spices have been the result of several recalls due to filler items being undeclared allergens.


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Nalathu

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Posted 01 June 2023 - 11:24 AM

I would think you would still have to declare this on your label even though it is a promotional product.  A spice packet would set up alarms as spices have been the result of several recalls due to filler items being undeclared allergens.

Hi Scotty_SQF,

 

Thanks this is good input!
I look for further explanations with regards to any special sections or codes of the FDA & USDA regulations.

 

:spoton:


kfromNE

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Posted 01 June 2023 - 12:10 PM

Spice powder - so I assume no meat items in it. So FDA regulations is what you need to look at.


G M

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Posted 01 June 2023 - 09:49 PM

 

Dear All,
 
I would like to seek your insights on a matter regarding the launch of a free giveaway spice powder product.
Our company is planning to distribute this product pack as a promotional item, and it will not be available for sale.
 
Given this unique circumstance, we are wondering if it is possible to exempt this product from
USDA and FDA compliance requirements specifically related to labeling.
 
I would greatly appreciate your expertise and input on this topic.
 
Thanks!

 

 

What specifically are you wanting to get an exception to?  For safety reasons people still need to know what's in it and where it came from if a problem is detected later.


SQFconsultant

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Posted 02 June 2023 - 01:21 AM

Client has used their standard label but added a self stick label strip that says...

NOT FOR INDIVIDUAL RETAIL SALE - FREE PROMOTIONAL PRODUCT.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

 

Glenn Oster Consulting, LLC

Consulting on: SQF Food Safety System Development, Implementation & Certification

eConsultant Retainer | Internal Auditor Training | Corrective Action Avoidance | XRP & XLM

 

Vineyard Haven, Martha's Vineyard Island, Massachussetts

Republic of these United States (restored)
 

www.GlennOster.com | 774.563.6161 | glenn@glennoster.com
 

 

 

 

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