6 replies to this topic

[ChristinaK]

I have been asked by our Sales team to look into whether we can sell certain imported food products as "clean label." They're been receiving comments from buyers, "Is it clean label?" as if that's some kind of Big Thing now?

 

From what I've found, there are no regulations around putting "clean label" on a product, there's a "Clean Label" certification program (of course there is), but nothing too helpful in defining what foods are considered "clean." I don't believe it would fall under the "health claims" or use of the word "healthy" regulations in 21CFR101. It looks like there's not a set definition, and that even the public aren't really aware of what it could mean?

 

We're currently redesigning/updating labels anyway, but I don't want to sign off on something that could end up with us in court trying to defend "clean label" if some rando decides that we're purposefully "misleading" consumers. You know how much everyone in the USA loves to sue over the tiniest things...(We only sell these imported items in the USA, btw)

 

We are adding a QR code to the label; it would direct consumers to our website ("for more product information, visit our website" with an arrow to QR code). If we define what we mean by "clean label" on our website, would that be enough? Ex: "Our products are CLEAN: Kosher-certified, no artificial colors, no artificial flavors, simple and recognizable ingredients." 

 

This is the "inspiration image" Sales sent to our Design team:

So any advice or guidance on "clean label?" Has anyone else dealt with this kind of thing before? Do you have resources or info you could share?

[jfrey123]

Interesting, and of course there's always some new company trying to profit off some new marketing idea.  I'd never seen the phrase "clean label" until reading it here.

 

I think you're on the right track and obviously aware of the caution needed to avoid running afoul of labeling claims.  I think it would behoove your company to avoid ripping the "clean label" phrasing to avoid a lawsuit:  there are currently at least two companies offering permission to use their "clean label" logo on packaging (Exactly What is "Clean Label" Food? - FoodIndustry.Com).  Might be worth some time to see if "clean label" is a trademarked phrase, but there is no FDA regulation discussing the phrase.  Now depending on how far it goes, FDA might get involved if companies want to use new buzzwords to circumvent the use of "Natural" on a label.  Lastly, someone needs to stay in communication with the sales team and your customers.  If your customers want actual "clean label" certification, your sales team needs to be careful about saying that your food meets that criteria unless your company wants to go through those private registrations.

[SQFconsultant]

In our new food company most of our product will be Clean Label - it's not a now its a big thing - it's been building for some years now and will get bigger.

 

Take the course attached to the certification, it is kinda worth it.

 

For us Clean Label means have ingredients that one understands and ingredients that are minimal, Gluten Free, Organic, Non-GMO, No GE, etc  Also, no chemical additives that have names that not even my bio chemist spouse can  understand.

 

Our Cranberry Jam for instance has Organic Cranberries, Organic Pectin, Organic Monkfruit (sweetener) - we are using an HPP system on this and most of our others. Oh, and we are packing in glass so not introducing more nano plastics into people, God knows every person on earth has enough of those already from food and drinks packaged in plastic.

 

Anyway, Clean Label is not next big marketing thing.

[kingstudruler1]

What a joke.   I only checked out the "Clean Label Project".   It doesnt appear that there is any standard.   All they do is purchase and test products for things such as heavy metals, pesticides, etc.   They have certified products that are easily identified as misbranded due to the "label" on suppliers web page.  

 

I thought it would be more like what Glenn is doing.   Simple ingredients, Minimally processed ingredients, etc.  I guess it kinda is.....

[SQFconsultant]

Kingstudruler - what you said: "What a joke.   I only checked out the "Clean Label Project" "

 

Oh gee, now I've got my partner running a search to see if there is more than 1 clean label organization - I think we are just going to create our own and skip all the organizations because after doing research on Non-GMO Project I was like Oh, shit - they are corrupted too!!!

[ChristinaK]

What a joke.   I only checked out the "Clean Label Project".   It doesnt appear that there is any standard.   All they do is purchase and test products for things such as heavy metals, pesticides, etc.   They have certified products that are easily identified as misbranded due to the "label" on suppliers web page.  

 

I thought it would be more like what Glenn is doing.   Simple ingredients, Minimally processed ingredients, etc.  I guess it kinda is.....

 

That's what I thought, too, but since I was super-unfamiliar I needed input from the forum.

 

I ended up coming up with 5-6 "catchy" but technically applicable phrases that we could use on our labels for each product based on a deep-dive into 21CFR101 and an analysis of each product's ingredient list. And a second, much longer, list of all the claims we shouldn't use because they cannot be substantiated. Our lead designer is putting them on a few mock-ups for Sales & upper management to review. I also came up with a rebuttal for any customers/buyers saying they want Clean Label.

 

Kingstudruler - what you said: "What a joke.   I only checked out the "Clean Label Project" "

 

Oh gee, now I've got my partner running a search to see if there is more than 1 clean label organization - I think we are just going to create our own and skip all the organizations because after doing research on Non-GMO Project I was like Oh, shit - they are corrupted too!!!

 

Glenn, as a head's up, you may want to avoid using the phrase "wholesome" on your product labels. I've found during my search that it's often interpreted as "healthy" so you'll want to look at 21 CFR 101.65(d) closely.

[G M]

The concept of "clean label" has been around in the food biz for decades.  It doesn't surprise me that someone has tried to market it with a certification though.

 

Being a pre-existing phrase or concept, as long as you leave the word 'project' out and don't mimic their logo style you can just slap 'clean label' on anything that isn't misleading.

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