Updating Your Nutrition Information: Everything You Need to Know
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Food manufacturers received a reprieve this year when the U.S. Food & Drug Administration (FDA) moved the compliance date for updating nutrition facts panels from July 26, 2018 to January 1, 2020. (Manufacturers with less than $10 million in annual food sales get an extra year, with a deadline of January 1, 2021.)
The new requirements aren’t just a design update; the nutrition information also gets an overhaul, with changes to the serving size, sugars, and nutrient headings required. By law, serving sizes on packaged food must reflect typical portions of an American consumer. The key to food packaging is to be transparent and honest and to never mislead shoppers.
Because the regulation regarding nutritional requirements has changed, you’ll need all new information for your panel. Large brands will have product testing and labs to support the data, but technology makes it a bit easier for smaller brands to analyze their recipes. Menutail is one of several online services for do-it-yourself nutritional labels.
Don’t just hand off the new panel to the packaging company and forget it. You’re changing your print plates now, so take advantage of the extra time and give your package a refresh. Visual updates and popular food trend certifications can make an impact at the shelf to set you apart from the competition. Here are the key components to some of the most well-known food terms and seals.
Organic
The term Organic is governed by the United States Department of Agriculture (USDA) and has 4 tiers of certification. A qualified team of certifying agents inspect the entire process of a product, including agriculture, processing aids, processing methods, and transportation methods. Annual inspections are required to maintain organic certification.
Once certified, the certifying agent’s information is required on the information panel of the package. Regardless of the tier of certification, the word organic should be used in the ingredients with each organic ingredient. This is a requirement for certified ingredients and can be noted with an asterisk statement if space is tight. Organic farmers who sell $5k or less are exempt from the certification process and are allowed to use the term organic but are restricted from using the seal or claiming their product is “certified”.
1. “100% Organic”
Products whose entire process meets all requirements are deemed “100% Organic” qualify to use the official USDA Organic logo. The term organic, and the percentage on the front of their package may be subject to restrictions on appearance and use of these elements, so don’t go too crazy with your package just yet. These products refrain from using substances from "The National List of Allowed and Prohibited Substances" as well as avoiding genetic modifications entirely (non-GMO we’ll cover more later in the article).
2. “Organic”
The second tier of organic certification requires at least 95% of the product’s process meet organic requirements of abstaining from specified substances and genetic modification. Once certified, the term “organic” and the percentage are allowed to be used on the front of the package; again, with restrictions.
3. "Made with Organic Ingredients”
Tier three calls attention to specific ingredients or food groups when a final product is at least 70% organic. The display panel of the package may include organic as long as the percentage accompanies it— and a blanket statement may be used—"Made With Organic Ingredients" / “Made with Organic [specified ingredients or food groups].”
As with the other tiers, these statements have restrictions. One example being that if a food group is mentioned in the blanket statement, every ingredient in that food group must be certified organic. The trust is in the details.
4. Less than 70% Organic Ingredients
The fourth and final tier pertains to products whose organic ingredients make up less than 70% of the final product. Products in this category are prohibited from using “certified” or “organic” on the main panel of their package; they are only allowed to list the term "organic" next to the specific organic ingredients on the information panel.
Gluten-Free
The FDA governs the term gluten-free, but there are certifications through two related entities based on end consumer market: packaged products vs. food service businesses.
Gluten-free certifications are essential for those with celiac disease—those allergic to gluten. People have different threshold reactions to gluten that can range from mild to life-threatening, making the accuracy of this regulation of critical importance.
Consumer Products
The Gluten-Free Certification Organization (GFCO) provides third-party certification for food products. The organization maintains close monitoring of products during processing, manufacturing, packaging, and transportation, and holds a tighter level of gluten parts per million (ppm) than the FDA.
All ingredients must contain 10 ppm or less, whereas the FDA only requires 20 ppm or less. This certification requires an annual inspection and renewal with regular, ongoing testing of high-risk raw materials and equipment. Barley-based ingredients are prohibited in all GFCO certified products because of their risk level.
Foodservice
The Gluten-Free Food Service (GFFS) is a training and accreditation program for foodservice businesses to prepare food to the highest gluten-free standards, providing a safe dining environment for those with allergies.
Facts Up Front
In 2014, the Grocery Manufacturers Association (GMA) and the Food Marketing Institute (FMI) launched the Facts up Front educational campaign. More and more manufacturers have adopted this voluntary initiative to provide shoppers a quick summary of calories and nutrients per serving size. Since this is a volunteer program, the facts displayed on the main panel of the package are generally dictated by the food category. Soda, for example, may only include the calories per can, while frozen dinners may include calories, fat, protein, and sodium content. This helps consumers more easily compare similar items to make an educated buying decision.
Non-GMO
GMO stands for Genetically Modified Organism. Non-GMO designation goes hand-in-hand with organic labeling because genetic modification is prohibited in organic certification. The Non-GMO Project is a non-profit governing body who verifies products that refrain from using genetic modification.
To use the Non-GMO Project Verified seal, products must go through the verification program conducted by an approved third-party. This certification is a separate entity from that of Organic certification but is worth the time and expense because it has a largely recognized following.
Vegan
Vegan products exclude meats, animal by-products (such as milk, eggs, honey, and gelatin), and generally refrain from animal testing. The government does not regulate vegan products so that the term can be used without certification; various agencies verify vegan products, the most well-known being Vegan.org.
People become vegan for various reasons, many are health, animal, or environmentally conscious individuals. Vegan marked products also help people with allergies to meats/dairy/etc. more easily find food options in a store or restaurant.
Kosher
Kosher is another food category that should be looked into if you’re taking time to look at your overall package design. Because of the background and the large Kosher community that exists, this certification is important to consider. It focuses on Jewish biblical laws, but is explained well by three thoughts: cleanliness, purity, and quality. Pork is not a Kosher ingredient, nor are certain cuts of other meats. Dairy products and meat products are kept separate in storage, preparation, and consumption.
The two most well-known certifying agencies are the Union of Orthodox Jewish Congregations (OU) and the Organized Kashrus Laboratories (OK). Other certification entities generally use a visible "K" in their seal to appeal to those unfamiliar with lesser-known agencies. These symbols can be accompanied by the letter "D" for Dairy, "P" for Meat, or the word Pareve/Parve—products that can be consumed with either meat or dairy.
Design Review
We’ve listed many options for labeling your product. There’s a danger in overloading your package front, so you’ll need to consider your target market and the value of each seal or certification to your brand story. Once you’ve settled on the product features and benefits you need to communicate, review the entire package design.
One option to alleviate clutter is to create branded notices for the front of your package and move some of those bulky seals to the back. Emmy’s Organics sells cookies in threes. Their packaging is small, yet they find the room for five certifications. Using their brand colors and fonts in place of some of the seals on the front of the package keeps the clean look of their brand without compromising their certification selling features.
Image: Emmy's Organics
Package design is your best asset for winning sales at the shelf. Cast a critical eye over your brand. Do your colors stand out? Can you tighten up the design to reduce visual clutter? Is it easy to identify the brand, style, and flavor of your product?
Put all your product information in one place and give it a thorough review before starting your packaging revision project. Tip: We find that using spreadsheets for data-driven projects are a great way to catch errors and omissions. It’s easy to overlook fine details when the information is spread across several documents. The visual organization of an Excel chart makes it easy to compare like content.
Many companies that own the printing and production equipment required to create packaging will give design away “for free” as an incentive to bring down the unit cost. Proceed with caution. The well-meaning staff of a prepress department may have the technical skill to update your art, but likely are not skilled in brand building and marketing messaging.
We have worked in partnerships where we design the master package and direct staff for additional SKUs, reviewing proofs and providing feedback to ensure the brand story is not compromised throughout the process.
Contact us for more information about package design, data-driven design, and our product launch processes.