Every packaged food has to say what it is on the front panel, the principal display panel: its statement of identity. It's the name a federal standard requires, if there is one; otherwise the common or usual name, such as "tortilla chips"; otherwise a descriptive name. A fanciful name, like a brand or flavor name, is enough on its own only when the food is obvious and the public commonly uses that name for it. If the food comes in forms, whole, sliced, strips, the form is part of the name, unless it shows through a window or a picture. The statement goes in bold type, in a size related to the biggest print on the panel, parallel to the base of the package. And a food that substitutes for and resembles another but is nutritionally inferior must say "imitation". In the example below, an Arizona chip maker fixes its bag fronts.
The short version
- Say what it is on the front panel: the statement of identity.
- Use the standard's name if there is one, then the common or usual name, then a descriptive one.
- A fanciful name alone works only when the food is obvious and the name is common.
- Include the form, strips or rounds, unless it shows through a window.
- Bold type, sized to the biggest print, parallel to the base.
- A nutritionally inferior substitute says "imitation".
- TaroStack keeps each product as a recipe and each batch as a lot. More below.
Which name
| The food | Statement of identity |
|---|---|
| Has a federal standard of identity, such as jam or peanut butter | The standard's name, or a different name if it doesn't meet the standard |
| Has a common or usual name, such as tortilla chips | That name |
| Has neither | An appropriately descriptive name |
| Obvious, with a fanciful name the public uses for it | The fanciful name can stand alone |
| Comes in forms: whole, sliced, strips, rounds | The form too, unless it shows through the package or a picture |
Foods with a standard are in standard of identity food, and where the net weight goes on the same panel in net weight labeling requirements.
The rules
| Rule | Where |
|---|---|
| On the front | The principal display panel bears a statement of identity as one of its principal features (21 CFR 101.3(a)) |
| Which name | The name a federal law or regulation requires; otherwise the common or usual name; otherwise an appropriately descriptive term, or a fanciful name commonly used when the food's nature is obvious (101.3(b)) |
| Forms | The optional form, whole, slices, diced, is part of the statement unless visible through the container or shown in a picture (101.3(c)) |
| Type | Bold, sized reasonably to the most prominent print on the panel, in lines generally parallel to the base (101.3(d)) |
| Imitation | A substitute that resembles another food and is nutritionally inferior bears "imitation" and the name of the food imitated (101.3(e)) |
This is general information, not legal advice.
An example: four bag fronts
Sol de Mesa Chips, the made-up tortilla chip maker in Tucson, Arizona, I use in these examples, sells four bags. A grocer asked what "Fire Dust" was, so the owner went through every front panel:
| Bag | Front before | Front now | Why |
|---|---|---|---|
| White corn chips | "Sol de Mesa" | "Sol de Mesa White Corn Tortilla Chips" | The brand isn't a statement of identity |
| Chile lime chips | "Fire Dust" | "Fire Dust Chile Lime Tortilla Chips" | A fanciful name the public doesn't use for chips |
| Blue corn strips | "Blue Corn Tortilla Chips" | "Blue Corn Tortilla Strips" | The form, strips, is part of the name; the bag has no window |
| Restaurant bag, 5 lb | "Tortilla Chips" in small type on the back | The same name, bold, on the front | It belongs on the front, sized to the brand |
"Fire Dust" stayed, because the brand likes it, but now it sits beside the common name in bold type. The strips come in a bag without a window, so "strips" goes in the name; a bag with a window would show it. The chip maker's year is in tortilla chips business plan.
Get the checker
Download the statement of identity checker. One sheet: each product, the name on its front, whether it has a standard of identity and uses its name, whether the front shows only a fanciful name, and whether the form shows; what to change 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 sorts the names. A new flavor printed on last year's bag, or a recipe that drifts away from its standard, can make a correct front panel wrong without anyone touching the label.
How TaroStack does it
TaroStack keeps each chip 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 chip 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.