FDA labeling - intervening material?

Hello!

We are in the process of redesigning the back of our package. In my research, I found that:

"Label statements are required to be placed together without any intervening material. Label statements include the name and address of the manufacturer, the ingredient list, nutrition labeling, and allergen labeling. Information that is not required by the FDA is considered intervening material and is not permitted to be placed between the required labeling."

What exactly counts as intervening material? Is this just text and images? The marketing team has placed a clear window below our allergen contains statement and above our company name and address. Should I have them move it elsewhere?

Thank you,

Stephanie

Clear window so that you can see the product should be ok.  As I try and picture it - it seems odd though

Its usually things like barcodes, best buy dates, or marketing print that is the issue.  So yes print / graphics is what you need to look out for. 

I still have nightmares of the marketing department waltzing into my office with a stack of proofs.  

I'm glad I'm not the only one! I feel like the bad guy breaking it to them what we can and cannot do and say. 

I have always taken it literally and insisted on just keeping the required elements together, period.  Also, note that these elements are supposed to be the first thing a consumer would encounter when flipping over the package- so I always try to put them on the left side of the panel. Agreed that it is no fun trying to convince the marketing people that this is the way to go, though.

I'm glad I'm not the only one! I feel like the bad guy breaking it to them what we can and cannot do and say. 

tomatoes are naturally high in glutamates / tomatoes are natural = MSG can be labeled as natural flavor.   Was always one of my favorites.    

i don't know how many times Ive written-  1/16 inch measured by lower case "o"