Are you messing up the most straightforward part of food labeling?

Posted on June 06, 2023 by

If you’re launching a food product, one of the first things your label needs is a statement of identity. Simply put, this statement tells the consumer what your product is. It’s the name of the food you’re selling.

In some cases this will be included naturally in the naming of your product, but depending on your branding you may need to add the common name of the food or an appropriately descriptive name. While this step is generally straightforward, you need to understand the rules to properly craft a statement of identity. And, yes, many brands mess this up!

Understanding the FDA’s Statement of Identity

The FDA considers the statement of identity to be a crucial feature of any packaged food product. As such, it’s required to be one of the principal features on the principal display panel. In other words, the statement of identity must be prominently placed on the front of your packaging. To describe what it means to be a “principal feature”, the FDA says that it must be in bold type and “in a size reasonably related to the most prominent printed matter.” As general guidance, they have recommended that this should be at least half the size of the largest print on the label. Further, the text must be parallel to the way the package rests when it is displayed.

FDA Statement of Identity Examples

How do I determine the correct statement of identity?

First, you need to figure out if there is an existing name that is specified or required by any Federal law (for instance, a food like macaroni has standards of identity - more about that below). If that doesn’t exist then you need to use the common or usual name for the food (for example, the brand Cheez It is classified under snack crackers). You can find existing food categories here. It would be considered misleading to label a food that has an established name with a new name. However, if that doesn’t exist, you can use an appropriately descriptive term, or when the nature of the food is obvious, a fanciful name commonly used by the public for such food. For example, vanilla wafers are allowed as a commonly used fanciful name.

Statement of Identity vs Standards of Identity

It’s important to keep in mind that your statement of identity must conform to the standards of identity (when those exist). The standard of identity is a food's composition and the statement of identity is its name. So if your statement of identity is “strawberry jam” then the contents of your product must meet the standards of jam set by the FDA. There have been incidents where products that were represented as fruit jams did not actually contain enough fruit to be classified that way. You can find the FDA’s standard of identities here.

Imitation Products

Another place where manufacturers can run into trouble is if they are using an imitation product and do not clearly label it as such. An imitation product is something that is a substitute for and resembles another food but is nutritionally inferior. For instance, the infamous “American Cheese” falls under the standard of identity of pasteurized process cheese. Specifically, American Cheese is defined as being made of cheddar cheese, washed curd cheese, colby cheese, or granular cheese or any mixture of two or more of these. However, there is an imitation product that is designed to look and taste very similar (at least in theory). In this case, the word “imitation” needs to precede the food it’s imitating (e.g. Imitation Pasteurized Process Cheese) in the same size and prominence to avoid being misbranded.

Imitation American Cheese

Dietary Supplements

If your product is a dietary supplement, it will also need a statement of identity. In this case, the statement can simply say “dietary supplement.” You are also allowed to replace the word “dietary” with the specific dietary ingredient, for example, “iron supplement”.

Having a proper statement of identity creates transparency for consumers. Since food safety is so important, even something as seemingly simple as stating the name of the product has loads of documentation to sift through. And it only gets more complex from there…but don’t worry. If you’re working on nutrition labels, ingredient lists, or even trying to get a handle on costing, ReciPal has simple solutions that take the headaches out of getting retail ready.

About Jack Scotti

Jack Scotti ReciPal

Jack Scotti is the director of marketing at ReciPal. Prior to joining the team he was a founder of Story2, an edtech company that teaches people how to advocate for themselves through the neuroscience of storytelling. One of the first activities in any Story2 workshop was to share a memorable meal story. So even before working in the food industry, he got to experience the amazing way food connects us all. (Ask him about his family’s feast of the 7 fishes or only eating ravioli in multiples of four.) Now, he couldn’t be more excited to help food business create more dinner table memories.

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