A packaged food's label names a manufacturer, packer or distributor and its place of business: the street address, city, state and ZIP, though the street can go if the business is listed in a current city or phone directory. A corporation uses its actual corporate name. When the business named on the label didn't make the food, as when a co-packer makes it, the name has to be qualified with a phrase that tells the connection: "Manufactured for", "Distributed by", or other words that say what's true. The co-packer's own name doesn't have to appear. A label can show the principal place of business instead of the plant's address, unless that would mislead. In the example below, a South Carolina sauce maker relabels as a co-packer takes over.
The short version
- Name the manufacturer, packer or distributor, with its place of business.
- Street, city, state and ZIP; the street can go if you're listed in a directory.
- A corporation uses its actual corporate name.
- If you didn't make it, say so: "Manufactured for" or "Distributed by".
- The co-packer's name doesn't have to appear.
- The principal place of business can stand in for the plant, unless misleading.
- TaroStack keeps each product as a recipe and each batch as a lot, co-packed or not. More below.
Which wording
| Who made it | On the label |
|---|---|
| You, in your own kitchen | Your name and place of business, no phrase needed |
| A co-packer, under your brand | "Manufactured for" or "Distributed by" your name, with your address |
| You, under another business's brand | Their name, qualified, such as "Distributed by" them |
| You, at a second plant | Your principal place of business, unless misleading |
Finding and contracting a co-packer is in how to find a co-packer and co-packing agreement template.
The rules
| Rule | Where |
|---|---|
| Name and place | The label names the manufacturer, packer or distributor and its place of business (21 CFR 101.5(a)) |
| Corporate name | A corporation's actual corporate name, with or without its division; others, the name the business operates under (101.5(b)) |
| Qualifying phrase | Where the named business didn't make the food: "Manufactured for", "Distributed by", or other wording that expresses the facts (101.5(c)) |
| Address | Street address, city, state and ZIP; the street may be omitted if listed in a current city or telephone directory (101.5(d)) |
| Principal place | The principal place of business may stand in for the actual plant, unless misleading (101.5(e)) |
This is general information, not legal advice.
An example: a co-packer takes over
Congaree Smokehouse Sauce Co., the made-up sauce maker in Columbia, South Carolina, I use in these examples, moved its barbecue sauces to a co-packer, and also makes a sauce for a grocer's own brand. Its labels:
| Product | Made by | Name and address on the label |
|---|---|---|
| Original barbecue sauce, before the move | Congaree, in its kitchen | Congaree Smokehouse Sauce Co., street address, Columbia, SC, ZIP |
| Original barbecue sauce, now | A co-packer in Georgia | Manufactured for Congaree Smokehouse Sauce Co., Columbia, SC, ZIP |
| Grocer's store-brand sauce | Congaree | Distributed by the grocer, with the grocer's address |
| Gift box of three | The co-packer, packed by Congaree | Manufactured for Congaree Smokehouse Sauce Co., Columbia, SC, ZIP |
Congaree is listed in the Columbia directory, so its street address can come off the co-packed labels, but it kept it, since grocers like a full address. The co-packer's name and Georgia address don't appear; "Manufactured for" says what's true. What the co-packer costs is in sauce co-packer.
Get the checker
Download the name and address checker. One sheet: each product, who makes it, the name on the label, and whether the street address is listed in a directory; the wording the label needs fills in. It's an ordinary Excel file with no macros, and it works in Google Sheets, LibreOffice and Numbers.
Where this stops working
The checker says what the label should say. Which co-packer's run a bottle came from, and which grocer got it, is what a question about one bottle needs, and the label doesn't say.
How TaroStack does it
TaroStack keeps each sauce as a recipe and each batch as a lot, so what's in a package, and who got it, is on record.
Recipes by weight. Each sauce is a recipe with its ingredients, so a change to one shows which products it touches.
Batches by lot. Each batch records the recipe and ingredient lots it used, and lot labels print for the cases.
Recalls. If a batch went out with the wrong label, one report shows every customer who got it.
| The job | Notebook | In TaroStack |
|---|---|---|
| Which products use an ingredient | Searched by hand | The recipes that use it |
| Which batch a package came from | Written on it | The lot on its label |
| Who got a mislabeled batch | Invoices | One recall report |
Recipes, batches, lots and recalls are on every plan, from $49 a month. The first 30 days are free, with no credit card. If you'd like a hand setting up, ask, and we'll do it with you.