A Brief Summary of Some Package Labeling Issues
Package labeling standards are set by a variety of organizations including the Food and Drug Administration (FDA) and other federal agencies, state governments, as well as foreign governments. I will concentrate on FDA mandated regulations concerning pesticide and food additives, labeling of bulk containers and consumer packaging of fresh fruit. I will conclude with a brief discussion of package labeling requirements in foreign markets.
The Northwest Horticultural Council (NHC) publishes a Wax and Postharvest Chemical Labeling manual that summarizes FDA regulations regarding package labeling. It is available from your local grower/shipper organization or directly from the Northwest Horticultural Council. This presentation will focus on specific facets of this summary information which were notable when we revised the manual last fall.
As you may know, bulk shipping containers must be labeled to identify any postharvest pesticides and postharvest food additives (i.e., waxes and coatings). This information must appear on the exterior of the container. Postharvest pesticide information is not required on retail or consumer packages. However, information regarding waxes and/or coatings is required on the outside of the consumer package and must be on the same panel as the name of the packer or distributor.
There are critical differences between the required wording on the container for postharvest pesticides compared with that regarding the use of postharvest waxes and/or coatings. Packers are required to list the pesticides with which the product has been treated and are allowed to do this by providing a statement on the bulk shipping container which says "May have been treated with chemical X or chemical Y to maintain freshness or extend shelf life."
In contrast, the requirements for providing information regarding whether or not a product has been treated with waxes, resins, sucrose polyesters or others, do not allow the packer similar wording flexibility. The bulk container or consumer package must affirmatively declare if the product has been treated. The use of a statement which declares that the product "may have been treated" is not allowed on either the shipping container or consumer package when providing information regarding waxes and/or coatings.
There are two other areas of regulation regarding labeling about which some members of our industry have recently raised questions. The first one concerns the edibility requirements for stickers now required by the trade for many sizes and grades of fruit. While the stickers are not required to be food grade, the labels, adhesive and ink used must be of the type approved for food contact.
Finally, with the increased official realization that a diet high in fruits and vegetables is among the healthiest, there is an increased interest in documenting this nutritional value. Nutritional labeling is currently voluntary but should any health or nutritional claim be made on the box or bag of fruit, the National Labeling and Education Act of 1990 applies, including full nutritional labeling. Anyone wishing to label with nutritional information should contact the appropriate industry promotion commission or bureau for detailed information involving a specific fruit.
One caution regarding exports: even if a nutritional label conforms to U.S. regulations, it may be problematic in other markets, where nutritional content for a specific fruit does not match the standards set by the U.S., or where other local labeling standards may exist.
We plan to revise the Wax and Postharvest Chemical manual in the next three months. If any member of our industry has any suggestions for corrections or modifications, please contact our office with the appropriate information.
I would like to share some thoughts about foreign language labeling requirements now newly enacted in a number of export markets. The Northwest Horticultural Council's Export Manual, which is available to any member of the domestic U.S. fruit industry, attempts to track foreign language labeling requirements in a number of export markets. We work in conjunction with USDA's Foreign Agriculture Service (FAS) to ensure that any proposed regulations require only useful and necessary information for consumers. Therefore, we routinely oppose requirements for foreign language labeling of bulk shipping containers not normally seen by consumers. However, we are not always successful and labeling of the bulk containers is required in some countries. Often the exact information required and the format for this information is not always clear from the regulations supplied by official sources in those countries. In these cases, while we will continue to work with FAS to provide the needed clarity, shippers should closely communicate with their export customers to determine the requisite information which will allow product to clear the point of entry promptly.
Dr. Michael J. Willett, Technical Issues Manager
Northwest Horticultural Council
6 South 2nd St., Room 903, Yakima, WA 98901
14th Annual Postharvest Conference,
March 10-11, 1998