Getting The Business Address Right
Posted on February 10, 2016 by Nili
Food packaging and labeling is a complicated business with reams and reams of rules, regulations, decisions, and guidance documents. So when we find something that we can share with you to clear up any possible confusion, we do. One of the many things that seems straightforward but trips many people up is the business address (also known as the signature or place of business). Here's what you need to keep in mind.
Every Package Needs to Have an Address
We'll repeat: every package needs to have an address. The point of this requirement is to allow people to find your physical place of business, not to contact you. So you cannot use a P.O. Box to fulfill this requirement. The address has to be a physical location. You can provide different general contact information somewhere else, but you still have to give the location of your business to satisfy the FDA requirements. If your principal place of business is different from where you manufacture, pack, or distribute your food, you can use your main business address on the label as long as that won't be misleading.
What's confusing is that in some places the FDA calls this just a "Business Address", which would imply a P.O. Box would be OK. However, in the actual documents it is referred to as the "Place of Business", which means the actual location where business is conducted and can't be a P.O. Box. This still wasn't completely clear to us, but after reading through a few warning letters from the FDA to businesses like Kind Bar it became much clearer. Granted, they were going after them for mainly other issues, but the point is that "the name and the place of business has to completely or accurately declare the place of business".
You have to state the actual corporate name of either the manufacturer, packer, or distributor. If you're an individual, partnership, or association, you show the name under which you conduct your business. If you're the manufacturer of your product, you don't need any qualifying description to go with your name. Otherwise you need to explain the relationship of the business to the product by saying "manufactured by" or "distributed by" or "packaged by."
The address must include the city, state, and zip code of the primary location of the business. If your business is listed in a common directory and can be easily found that way, you don't need to include a street address. But if it can't be found that way, either because it's not in the directory or because you have multiple locations and it's not obvious which is the primary place of business, you are required to include a street address (street number and name, suite or building number, etc.). This is where that post office box won't work.
Also remember that there can't be any intervening material between the nutrition facts panel, the ingredient list, and the address. That's why we give you the option to put all that information in through ReciPal.
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