Ingredient Labeling: What's In a Food?

by Food and Drug Administration (FDA)

Mr. Doodle can call his hat whatever he likes. Pasta makers, however, have long had to be very specific about what they call "macaroni." That's because since shortly after the Federal Food, Drug, and Cosmetic Act was passed in 1938, macaroni, along with some other foods people commonly prepared at home in those days, was exempted from the law's requirement that food manufacturers list their products' ingredients on the food label. Instead, the new act provided for "standards of identity" — prescribed recipes — for these foods, which the manufacturers had to follow.

"The law resulted in standardized recipes for such foods as dairy products, mayonnaise, ketchup, jelly, and orange juice," says Elizabeth Campbell, director of the programs and enforcement policy division in the Office of Food Labeling of FDA's Center for Food Safety and Applied Nutrition. "When a consumer bought a jar of jelly she knew it would have at least 45 percent fruit, as the standard provided, because that's what it takes to make jelly," she explained. "It's roughly half fruit and half sugar. People knew that because they used to make it themselves."

Well, maybe so, but we're in the '90s now, and with the fast pace of today's lifestyles, homemade breads and jellies mostly exist in Grandma's memories. It can hardly be taken for granted that people still know what's in those standardized foods. And yet, more and more, health-conscious consumers and people with dietary restrictions want and need to know what's in the foods they buy.

So, the law is changing to catch up with the times. FDA now requires that ingredients for all standardized foods be listed on the label, the same as for all other foods. This is one of several provisions of a final rule published in the Jan. 6, 1993, Federal Register concerning declaration of ingredients on food labels. (The U.S. Department of Agriculture requires full ingredient labeling on all meat and poultry products, including standardized products, such as chili or sausages.)

Two of the provisions of the rule on declaration of ingredients respond directly to the 1990 Nutrition Labeling and Education Act (NLEA). One is the requirement to list ingredients in standardized foods; the other requires the label to list FDA-certified color additives by name.

Before passage of the NLEA, the Food, Drug, and Cosmetic Act did not require flavorings, colorings or spices to be identified by their common or usual names. Instead, they could be declared collectively under the general terms "flavorings," "spices" or "colorings." Under the NLEA, however, color additives that FDA certifies for food use — FD&C colors Yellow No. 5, Red No. 40, Red No. 3, Yellow No. 6, Blue No. 1, Blue No. 2, and Green No. 3, and their lakes (specially formulated nonsoluble colors) — now must be declared on all foods except butter, cheese, and ice cream. Colors exempt from certification, such as caramel, paprika, and beet juice, do not have to be specifically identified; they can still be listed simply as "artificial colors."

People often look to the ingredient label for health reasons — perhaps to avoid substances they are allergic or sensitive to — or for religious or cultural reasons.

Manufacturers must comply with the requirements for ingredient listing of standardized foods and declaration of certified color additives by May 8, 1993. Other provisions of the final rule become effective May 8, 1994.

Caseinate

If it says "nondairy," does it mean no milk? Many people are not aware that certain products claiming to be nondairy, such as some coffee whiteners, contain a milk derivative called caseinate, in this case used to whiten effectively.

"People expect there to be no milk ingredients in products marketed as dairy substitutes," Campbell says, "but some states require the label 'nondairy.' This issue is particularly important for people with milk allergies. The nondairy label may lead consumers to think that caseinates are not milk derived. Furthermore, it guides people away from even checking the label for milk-derived ingredients."

Under the new rule, caseinate will have to be identified as a milk derivative in the ingredient statement when it's used in foods that claim to be nondairy. This requirement will help to flag it for casein-sensitive people.

Protein Hydrolysates

Consumers will get more information about protein hydrolysates in their food, too. Hydrolyzed proteins (proteins broken down by acid or enzymes into amino acids) are added to foods to serve various functions. They can be used as leavening agents, stabilizers (to impart body or improve consistency, for example), thickeners, flavorings, flavor enhancers, and as a nutrient (protein source), to name a few uses.

Since the law does not require flavors to be identified by their common or usual names, some in industry have made a practice of declaring protein hydrolysates as "flavorings" or "natural flavors" even when they are used as flavor enhancers — a use not exempt from declaration. After reviewing the data, FDA concluded that protein hydrolysates added to foods as flavorings always function as flavor enhancers as well and, as such, must be declared by their common or usual name.

The source of protein in hydrolysates used for flavor-related purposes also must be identified. Previously the general terms "hydrolyzed vegetable protein," "hydrolyzed animal protein," or simply "hydrolyzed protein" were permitted, but the new regulation requires identification of the specific protein source, such as "hydrolyzed corn protein" or "hydrolyzed casein." There are two reasons for this.

First, the law requires that the common or usual name of a food should adequately describe its basic nature or characterizing properties or ingredients. FDA reasoned that the more general terms "animal" and "vegetable" don't meet this requirement because protein hydrolysates from different sources best serve different functions. Manufacturers select protein hydrolysates from specific sources depending on how they will be used in a product. Hydrolyzed casein is generally used in canned tuna, for example, whereas hydrolyzed wheat protein is used in meat flavors.

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FDA is A United States government body that oversees medical devices, including contact lenses, intraocular lenses, excimer lasers and eyedrops. In the US, these products must be approved by the FDA before they can be marketed.