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FDA allows ingredient swaps without label changes

May 26, 2020 from Foodt Dive:

• "Companies making minor formulation and ingredient changes to their products because of scarcity due to the coronavirus pandemic do not have to make corresponding changes to their labeling, according to new guidance from the FDA."

  "This flexibility only applies to small changes. Labeling changes would be required if a substitution occurred that added a commonly allergenic ingredient, if the substituted ingredient made up more than 2% of the weight of the finished product, if a missing ingredient was a defining characteristic of the product or if the change made an impact on health claims or functionality."

  "The same guidance document also gives flexibility to operators of 20 or more vending machines. FDA says it will not object if they are unable to provide calorie information on foods that are sold during this time. "

"A plain reading of the guidance basically shows that the regulations only allow manufacturers to make swaps that many consumers might not care about or even notice — like unbleached flour for bleached flour, or leaving green peppers out of a quiche that contains four other vegetables. The FDA notes this is necessary because the pandemic has strained supply chains everywhere, and specific ingredients may see shortages as time goes on. This guidance doesn't allow a manufacturer to make big changes, like leaving raisins out of cinnamon raisin bread, or swapping alternative flours for whole wheat in a muffin recipe."

"However, these new regulations don't require any public disclosure of these changes." "Instead of just making a swap in the factory, manufacturers could publicize the changes on social media, their brand website, by information displayed at the point of sale or through stickers on packaging alerting consumers of a potential change."

"Consumers are more likely to be understanding about changes as long as they are informed. And highly sensitive consumers, including those with food allergies, will continue to place trust in the brands that take care to let them know that manufacturing practices during the pandemic will keep them safe — or that temporary changes may result in new risks."