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?