4 replies to this topic

[Sean Xia]

Hi everyone, this has brother me for a while. In Canada, it is clearly stated that from the 3rd generation of sub-ingredients, it is no longer required to declare its components. But I couldn't find anything of similar nature in the US regulations. For example, if we use a marinated meat as an ingredients, which contains a sauce as a component. Then the sauce contains a pickled vegetable, that contains vinegar, do we still need to declare the components of the vinegar?

 

Thank you for all your input.

[Slab]

No, "3rd gen" is not required. However, it cannot contribute significantly to the nutritional analysis, and must follow allergen/intolerance substance declaration.

[Sean Xia]

No, "3rd gen" is not required. However, it cannot contribute significantly to the nutritional analysis, and must follow allergen/intolerance substance declaration.

Thank you, do you have a regulatory reference for that?

[Slab]

21 CFR 101.4(b)(2)

 

Your ingredient list will either fall under (i) or (ii)

[Sean Xia]

Thank you, but this does not say that the 3rd gen are exempted to be declared. I am a little concern if an inspector challenging us for not expand the 3rd gen components.