A chemical preservative added to a food goes in the ingredient list with two things: its common or usual name, and a separate description of what it does. FDA's examples of that description are "preservative", "to retard spoilage", "a mold inhibitor", "to help protect flavor" and "to promote color retention". So a tortilla with calcium propionate lists "calcium propionate (to retard spoilage)", and a hot sauce with sodium benzoate lists "sodium benzoate (a preservative)". An ingredient that's in the food for another reason, such as vinegar for flavor and acidity, is listed by its name. In the example below, an Arizona salsa and tortilla maker adds a preservative to its grocer tortillas.
The short version
- A chemical preservative gets its name and its function in the ingredient list.
- Functions FDA gives: "preservative", "to retard spoilage", "a mold inhibitor".
- Also "to help protect flavor" and "to promote color retention".
- Example: "calcium propionate (to retard spoilage)".
- Ingredients there for other reasons are listed by name.
- A "no preservatives" claim has to be true of every ingredient, sub-ingredients included.
- TaroStack keeps each recipe with its ingredients, so a change shows which products it touches. More below.
How it reads
| Preservative | In the ingredient list |
|---|---|
| Calcium propionate in tortillas | "calcium propionate (to retard spoilage)" |
| Sodium benzoate in hot sauce | "sodium benzoate (a preservative)" |
| Potassium sorbate in a dressing | "potassium sorbate (a mold inhibitor)" |
| Ascorbic acid to keep fruit from browning | "ascorbic acid (to promote color retention)" |
| Rosemary extract to protect flavor | "rosemary extract (to help protect flavor)" |
Where each ingredient goes in the list is in ingredient list order, and what an "all natural" claim can and can't say in all natural label claim.
The rules
| Rule | Where |
|---|---|
| Name and function | A food with an added chemical preservative declares the ingredient's common or usual name and a separate description of its function, such as "preservative", "to retard spoilage", "a mold inhibitor", "to help protect flavor" or "to promote color retention" (21 CFR 101.22(j)) |
| Ingredient order | Ingredients in descending order of predominance by weight (21 CFR 101.4(a)) |
This is general information, not legal advice.
An example: a longer date for grocers
Saguaro Salsa Co., the made-up salsa and tortilla maker in Tucson, Arizona, I use in these examples, dated its handmade tortillas 3 days. A grocer wanted a week, so the owner tested a preservative for the grocer packs and rewrote the lists:
| Product | Preservative | In the ingredient list |
|---|---|---|
| Flour tortillas, market packs | None | "Flour, water, lard, salt, baking powder" |
| Flour tortillas, grocer packs | Calcium propionate | "Flour, water, lard, salt, baking powder, calcium propionate (to retard spoilage)" |
| Roasted tomato salsa | None: vinegar for acidity and flavor | "... vinegar, lime juice ..." |
| Habanero hot sauce | Sodium benzoate | "... vinegar, salt, sodium benzoate (a preservative)" |
The market packs stay without a preservative and keep their 3-day date, from tortillas shelf life; the grocer packs get the preservative and a date set by a new shelf life study. The salsa's vinegar is an ingredient for acidity and flavor, listed by name. Packs and labels are in how to package tortillas for sale.
Get the checker
Download the preservative labeling checker. One sheet: each ingredient, whether it's added as a chemical preservative, and its function; how it reads in the ingredient list 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 writes the line. Two versions of one tortilla, with and without the preservative, going to different customers, is where the wrong label ends up on the wrong pack.
How TaroStack does it
TaroStack keeps each tortilla 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 tortilla 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.