My Q&A with Silliker (Part 2 of 2)

Here is Part 2 of my Q&A with Silliker, which provides some great insights on current labeling issues and common mistakes by food companies.   You can find Part 1 of the Q&A here.  My thanks again to all the great people at Silliker.

Food Identity Blog:    For manufacturers of prepared foods, are there particular labeling-related issues (e.g.,  allergens, GMO ingredients, calorie counts) that present the biggest challenges in terms of preparedness and compliance over the next 1-2 years as compared to other issues?  Please explain.

Silliker:  Sodium, front-of-pack labeling, and ‘all natural’ claims are some of the greatest challenges facing manufacturers of prepared foods.   Efforts to reduce sodium in processed foods and implied claims associated with front-of-pack labeling schemes are challenging in terms of product development and reformulation.  Moreover, it seems the use of ‘all natural’ on product labels has become a common reason for labeling violations resulting in numerous FDA warning letters and consumer lawsuits.

Manufacturers have been advised to reduce sodium in processed foods, but finding salt alternatives acceptable to consumers has been a challenge.  Food companies, industry groups and individuals submitted more than 500 comments earlier this year in response to a federal initiative to reduce sodium in processed foods.  While the majority of food companies voiced opposition to mandatory reductions in sodium, several comments expressed concerns about the cost of salt replacement technologies and described formulation problems associated with salt alternatives in processed foods.

As the FDA developed draft regulations for front-of-pack food labeling, the food industry advanced a voluntary labeling scheme for manufacturers. The Grocery Manufacturers Association (GMA) issued revised guidelines for its ‘Facts Up Front’ nutrient-based labeling system.  The Facts Up Front icon is expected to proliferate on food packaging throughout North America.  The labeling icon was developed to highlight significant information from the Nutrition Facts panel, including calories, saturated fat, sodium and sugar per serving.

The use of ‘all natural’ claims on food products has prompted complaints to the FDA from consumer advocacy groups as well as numerous legal challenges filed on behalf of consumers.

The use of ‘all natural’ or ‘100% natural’ claims in food labeling is a common problem for manufacturers due to the lack of an adequate regulatory definition for the term ‘natural’ for food.

Food Identity Blog:   What are the most frequent mistakes you see from small to mid-sized food manufacturers with regard to labeling and regulatory compliance?

Silliker:  Common food labeling errors in North America include the improper formatting of the Nutrition Facts panel in terms of nutrient rounding rules and graphics, undeclared ingredients or improperly identified ingredients, and nutrient content claims failing to meet FDA criteria.

Labeling errors associated with the nutrition facts panel might increase in the future as the FDA is planning to modify certain reporting requirements.   The FDA is expected to revise the Nutrition Facts panel to emphasize calories and more accurate serving sizes, but to diminish the use of  daily percent values for fat, sodium, and carbohydrates.  Moreover, the FDA is considering the declaration of ‘added sugars’ on the Nutrition Facts label.  The 2010 Dietary Guidelines and other public health endeavors in recent years have advised consumers to limit the dietary consumption of ‘added sugars’.  The proposed changes would support ongoing federal efforts to curb obesity.

Food Identity Blog:  Any final words of advice for food companies seeking to protect their brand’s value?

Silliker:  Food companies are confronted by emerging scientific challenges and an increasingly complex regulatory maize in the U.S. and abroad.  As the FDA moves forward with new food safety regulations and increased enforcement of labeling violations, food companies must be prepared.   For years, the expertise of independent laboratories and consultants has been relied upon to guide the industry through this labyrinth.  Whether nutritional labeling or label claims, if a food company has strong, documented data supporting their position, their risk of regulatory issues is greatly reduced.  If this data is produced and verified by an objective external testing laboratory, the risk is further reduced.


Silliker recently opened a new 71,000 square-foot, state-of-the-art facility providing expert chemical and microbiological testing services for companies throughout the food supply chain.  Located in Crete, IL, the Silliker Solution Center leverages the latest technologies and harnesses innovative solutions to address both routine and challenging food industry needs.

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