How to complete a Food Label Review

Undertaking an effective food label review makes logical business sense because one of the biggest causes of food recall world-wide is incorrect labelling. Regardless of where a food company is located, there are regulatory requirements stipulating that the information provided on food labels is not only correct but also not misleading to the consumer. In this post find out more on how to perform an effective food label review along with how often you should be performing this activity.

What is a food label review?

A food label review is a process where you check your food packaging labels for compliance against the relevant food labelling legislation. If you export your product to any other countries outside of your country of manufacture, you may also need to review your product label against that countries food labelling legislation as well.

Requirements of Certification Standards

Most Global Food Safety Initiative (GFSI) recognised certification programmes, like SQF, BRC and FSSC22000, and also several customer-specific standards will mandate food labelling compliance.  These Standards will also require that food label reviews are also completed on a regular basis.

HACCP Mentor Food Label Review

Frequency for completing a label review

Whenever you are nominating the frequency at which you will review your food product labels, you need to consider at the least, the requirements of your certification standard. From what I have seen as an auditor, a minimum annual frequency of label review is required. Labels may also be required to be reviewed when there is:

  • A change to the recipe or formulation
  • A change to raw materials used in the finished product (especially if there are updated raw materials that contain previously unidentified allergens).
  • A change to the food labelling laws

Completing a food product label review

The easiest way to complete a food label review is to first design a checklist of all of the relevant sections that your food label has to have as applicable to your food labelling law. These may include things like (but not limited to):

  • Food product name and description
  • Product weight / measurement
  • Manufacturer’s details (name, address, contact)
  • Country of Origin
  • List of ingredients
  • Nutritional Information
  • Product Claims (e. Fat free, GMO free, High in Protein, Free Range, Organic)
  • Allergen or prescribed warnings
  • Date and traceability coding

The next part is the comparison exercise. This is where you get a copy of your product label or packaging and compare it against the requirements of your applicable legislation (the items that you have listed on your checklist). I do not suggest making this a ‘tick and flick’ activity. Actually document your findings on your checklist. For example, if it states ‘manufacturers details’, write what is exactly on the label onto your check list. This helps to strengthen the verification process and provides evidence that you have actually completed the activity.

The ingredient listing should also be verified at this stage. You can do this by comparing the finished product recipe against all of the raw material specifications. Make sure that you are reviewing the most current raw material specification as your supplier may have made changes since your previous review.

Documenting issues identified

Any issues that you identified, make sure that you document the corrective action that you took to rectify the non-conformance. Finally, when I do this activity for my clients, I always include a copy of the label or packaging that I reviewed. This helps with document control and knowing exactly what label was reviewed.


Responsibility for the Label Review

You can nominate a position or person to undertaken the food label review and depending on the amount of products that require a food label review, this may be a team of people. Whoever is allocated with the responsibility, ensure that they have adequate knowledge and skill in completing this task and also in what the legal requirements are. The reason that I say this is because it can become a very expensive activity if your product labelling is incorrect in the market-place. Undeclared allergens on food labels is one of the most common reasons for having to undertake a food recall. The cost of regulatory action and brand damage should also be of concern.

Access Free Webinar

Join Amanda Evans-Lara in this presentation as she demonstrates how to audit and review your food labels like a professional. Find out how to quickly identify key areas of review, recognise legitimate supporting evidence and implement an effective 3-step approach to auditing food labels. 

The session will also provide tools and takeaways to help you successfully audit food labelling requirements regardless of your current level of food labelling knowledge.

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