Labelling Standards

Ensuring Labelling Compliance against Regulatory, Industry and Customer Standards

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To define detail, scope and purpose.

Development

This information can be used to develop food safety and quality programs that meet the requirements of modern Regulatory, Customer and Industry Standards:

  • We take the time to explain the expectations and requirements of food safety and quality compliance as these relate to your food safety and quality programs.
  • You may choose to use our Premium Resources to build, enhance or upgrade your food safety and quality program.
  • We encourage you to share this webpage with any food compliance associates and peers you believe may benefit from our commitment to providing our users with user friendling information and resources to a achieve superior Food Compliance Culture.
  • We welcome your suggestions for additions of general or specific content through the haccp.com Contact Page.

Key Definitions for Labeling Standards

  • Indelible: Having the quality of being difficult to remove, wash away, blot out, or efface; incapable of being canceled, lost, or forgotten; incapable of being annulled.
  • Labeling: Labeling is the act of applying identification details to a food item.
  • Legible: Legibility indicates how clear text is visually and whether it is capable of being read or deciphered.
  • Nutritional Information Panel or NIP: A Nutritional Information Panel is a documented summary of the average nutrient and chemical values of a foodstuff.
  • Packaging: Packaging is the practice of enclosing or protecting products for distribution, storage, sale, and use. Packaging also refers to the process of design, evaluation, and production of packages.

Labeling Standards Development

When considering the development, documentation, and implementation of Labeling Standards within food safety and quality management systems, the following information should be considered to ensure effective outcomes:

About Labeling Standards

Packaging design and materials should provide adequate protection for products to minimize contamination, prevent damage, and accommodate appropriate Labeling. Labeling Standards procedures should be formatted to ensure that packaging conforms to relevant specifications which may be based upon regulatory or industry guidelines, or for customer requirements. Packaging materials or procedures mustn’t impact the safety or quality of the foods being packaged. Unused packaging should be handled and stored in a manner that does not compromise food safety or quality.

General Product Labeling

Depending on the type of food your customers are buying and the intended usage of the food, it may or may not require Labeling. There is generally no requirement for items produced for consumption within a premise to be labeled with details of ingredients and usage details. Labeling requirements for specific products or product groups are defined with the applicable food standards legislation.
General Labeling requirements for products for retail sale include:

  • Product name;
  • Manufacturer address and contact details
  • Manufactured on, Use By, Best Before Date. These dates must be objective regarding the type of food being packaged, and its intended use;
  • Ingredients, usually in ingoing descending order from most proportionate to least proportionate;
  • Allergy concerns, for example; Contains or May Contain any specified allergen.
  • Specific usage instructions, for example: “Keep refrigerated and use within 24 hours of opening”;
  • Nutritional Information Panel or NIP; The documented content of the Labeling NIP must be verified to ensure the information displayed is appropriate;
  • Country of origin declaration;
  • Net Weight and Gross Weight.

Labeling aims to provide consumers with information that will ensure they can make an informed decision regarding their choice of food and to ensure its safety at the time of consumption providing it has been handled and used according to the nominated requirements.
It is important to ensure that Labeling review activities are scheduled, conducted, and recorded on an ongoing basis to ensure labels are accurate and meet customer and regulatory requirements. The frequency for Labeling review activities is often nominated to meet customer requirements, though annually is a common minimum frequency.

Date Coding

Foods that have a relatively long shelf life such as canned products, cereals, and ambient storage items are generally labeled with a Best Before date. It is not generally illegal to sell these foods beyond the nominated best before date, but the product may suffer organoleptic or physical degradation due to its age.
Potentially hazardous foods with a short shelf life in which pathogenic micro-organisms can grow are generally labeled with a Use By date. It is generally a regulatory offense to have on display or sell food after the Use By date has expired, even if it appears to still be fit to eat. The Use By date generally expires at midnight on the date given.

Sub-contract Packaging and Labeling

In instances where sub-contracted packaging or Labeling activities are conducted, it is of utmost importance that the scope and purpose of interactions of such sub-contractors are documented, and agreed upon, both internally and by relevant customers.
It is generally not considered appropriate for food businesses to procure the services of a sub-contracted packaging or Labeling supplier without the prior consent of the customer for whom they manufacture foodstuffs. Such customer approvals often include verification of satisfactory standards, including the confirmation of food-grade packaging status.
In instances where Identity Preserved products are handled by sub-contracted packaging or Labeling suppliers, it is important to ensure that the integrity and “genuine” status of such foods are maintained. This is often facilitated through the establishment of assessment and testing routines between food businesses that may enter into sub-contracted packaging or Labeling arrangements to ensure the status of Identity Preserved products is not compromised.

Integrity of Product Labeling and Coding

Regardless of whether product Labeling and coding are pre-printed or applied as part of the packaging process, all forms of product identification and traceability must remain legible and indelible at all times.
Legibility checks are conducted to ensure that the print within the product Labeling and coding can be read and understood by the anticipated consumer group. It is also important to consider that regulatory guidelines often specify requirements for defining the legibility of product Labeling and coding.
Indelibility checks are conducted to ensure that the product Labeling and coding are permanent and will not be removed through unwanted means. When considering the indelibility characteristics of product Labeling and coding, it is important to consider circumstances through which such Labeling or coding may become illegible. For example, if the exterior of a frozen product becomes frosted during transport, the excess moisture on the product exterior could potentially cause the product label or coding to become illegible. Environmental conditions, such as high humidity within the packaging and Labeling area of the food business can also potentially impact the integrity of the applied Labeling.
Product assessments should be inclusive of Labeling and coding reviews to ensure ongoing compliance. Scheduled product Labeling and coding verification activities should also confirm the capability to continuously apply legible and indelible Labeling and coding. Where product coding is applied within the food business, verification activities are commonly inclusive of a review of the inks being used, the ink application systems and printers, and the surfaces upon which the ink is applied. Other product coding methods, including laser etching and imprinting, may also be verified through a scheduled activity.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Development requirements in relation to their items.

Labeling Standards Development Key Points

  • Labeling Standards programs must be developed to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • The Senior Management of your business facilitate a commitment to ensuring adequate resources to the development of your Labeling Standards program;
  • Should you require additional resources for the development of Labeling Standards program elements, please discuss this with the relevant Senior Management representative;
  • A properly developed Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly-developed Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To establish the developed detail in a viewable format to facilitate information.

Documentation

Document: A document provides guidance and/or direction for performing work, making decisions, or rendering judgments that affect the safety or quality of the products or services that customers receive.
Documented policies, procedures, work instructions, and schedules form the basis of any food safety and quality management system. The following documentation formats may be considered to ensure ongoing compliance with specified requirements for Labeling Standards:

  • Labeling Standards policy;
  • Labeling Standards development procedures;
  • Labeling Standards implementation procedures and work instructions;
  • Labeling Standards monitoring procedures;
  • Labeling Standards corrective and preventative action procedures;
  • Labeling Standards verification schedule;
  • Labeling Standards verification procedures;
  • Labeling Standards validation schedule;
  • Labeling Standards validation procedures;
  • Labeling Standards training procedures.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Documentation requirements in relation to their items.
You may wish to visit the Labeling Standards Templates section of haccp.com for examples of Labeling Standards documentation, record, and resource formats commonly applied within food safety and quality systems.

Labeling Standards Documentation Key Points

  • Labeling Standards programs must be documented to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • All documented Labeling Standards program elements must be controlled to ensure compliance;
  • Key documented Labeling Standards program elements should be available to your business team at all times to ensure they can facilitate required tasks;
  • A properly documented Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly documented Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To facilitate the application of the documentation.

Implementation

Implementation: Implementation is the application of documented food safety and quality system elements into the actual business operation.

The implementation of Labeling Standards within any food business requires genuine commitment from senior management, staff, and visitors to ensure the nominated goals of implementation are achievable on an ongoing basis. It is a step that requires significant planning and consideration of general and specific food business circumstances to ensure the outcomes of Labeling Standards do not negatively impact the safety and quality of the food items dispatched from the business.
Implementation of Labeling Standards must include a clear definition of responsibilities and authorities for all levels of participation by senior management, staff, and visitors to the site.
When implementing Labeling Standards within the food safety and quality system, you may wish to consider the following requirements before completion:

  • Communication and display of the Labeling Standards policy;
  • Completion of Verification and Validation of Labeling Standards development procedures;
  • Availability of Labeling Standards implementation procedures and work instructions;
  • Availability of Labeling Standards monitoring procedures and record templates where applicable;
  • Availability of Labeling Standards corrective and preventative action procedures and record templates where applicable;
  • Availability of the Labeling Standards verification schedule;
  • Availability of Labeling Standards verification procedures;
  • Availability of the Labeling Standards validation schedule;
  • Availability of Labeling Standards validation procedures;
  • Completion of Labeling Standards training procedures;
  • Completion of product design and development requirements related to Labeling Standards;
  • Completion of process design and development requirements related to Labeling Standards;
  • Completion of training for team members who have responsibilities and involvement within Labeling Standards;
  • Completion of competency approval for team members who have responsibilities and involvement within Labeling Standards.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Implementation requirements in relation to their items.

Labeling Standards Implementation Key Points

  • Labeling Standards programs must be Implemented to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • Your Labeling Standards program must be fully implemented as per relevant documented Policies, Procedures, and Work Instructions;
  • The implementation of Labeling Standards requires a commitment to the provision of resources by the Senior Management of your business;
  • A properly implemented Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly implemented Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To review, confirm and document evidence of the implementation against documented limits.

Monitoring

Monitoring: Monitoring is the act of reviewing and confirming measurable parameters of a defined process or product status.

Monitoring requirements within food industry sectors are generally identified against limits of acceptability defined within HACCP plans, implementation procedures, and work instructions. Monitoring usually includes some element of record-keeping, which may be maintained manually or through digital systems. It is important to consider that advancements in technology have spawned many systems and processes which are self-monitored and or self-adjusted when variances are identified. Regardless of the system used; The goal of any monitoring activity is to provide sufficient evidence that any limit of acceptability has been met.
Traditional Labeling Standards monitoring requirements include manual recording and the application of corrective actions when the results of monitoring are found to be outside acceptable limits. Corrective Actions should also generally be strongly linked to the monitoring process where applied to ensure full traceability of the applied actions.
Common monitoring activities and record formats may apply to Labeling Standards:

  • Packaging Monitoring Records: The use of packaging is commonly monitored as an element of in-line processes to ensure the correct packaging is used for the products being packaged. It is also important to ensure that Packaging is correctly sealed to ensure potential hazards are not caused by such seal deficiencies;
  • Labeling Monitoring Records: Labeling and other forms of product coding are also commonly monitored to ensure applications conform to regulatory, industry, and customer requirements. Criteria for product Labeling or coding, including size, content, legibility, and indelibility are important considerations for food product Labeling.
    If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Monitoring requirements in relation to their items.

You may wish to visit the Labeling Standards Templates section of haccp.com for examples of Labeling Standards documentation, record, and resource formats commonly applied within food safety and quality systems.

Labeling Standards Monitoring Key Points

  • Monitoring provides real-time confirmation and evidence that your risk-based FS&Q Controls are effectively implemented;
  • Labeling Standards programs must be monitored to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • Monitoring of Labeling Standards must be facilitated as per relevant documented Policies, Procedures, and Work Instructions;
  • Nominated monitoring records for Labeling Standards must be maintained as per relevant documented Policies, Procedures, and Work Instructions;
  • A properly monitored Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly monitored Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To apply “real time” interventions to documented monitoring limits.

Corrective Action and Preventative Action

Corrective Action: Corrective action is mandatory action to be taken when a deviation to the Quality System occurs, particularly to a Critical Control Point.
Preventative Action: At any step in the process where a hazard has been identified, preventative action must be put into place to prevent re-occurrence.
Corrective Action and Preventative Action are implemented to ensure that any identified non-conformance issues are documented, investigated, and rectified within appropriate time frames.
Corrective action is any action applied to regain control over a product, process, policy, or procedure that has been identified as being non-conforming outside nominated limits of acceptability.
Preventative action is any action applied to prevent any identified non-conformance from reoccurring.

The outcomes of corrective and preventative actions should result in regained process control after effective application. Specified corrective actions are commonly linked to the HACCP Plans and the food business certification process.
Below are Corrective Action and Preventative Action examples which may be associated with Labeling Standards related non-conformance:

  • Review of the Labeling Standards policy;
  • Review of Labeling Standards development procedures;
  • Review of Labeling Standards implementation procedures and work instructions;
  • Review of Labeling Standards monitoring procedures;
  • Review of Labeling Standards corrective and preventative action procedures;
  • Review of the Labeling Standards verification schedule;
  • Review of Labeling Standards verification procedures;
  • Review of the Labeling Standards validation schedule;
  • Review of Labeling Standards validation procedures;
  • Review of Labeling Standards training procedures;
  • Re-training in Labeling Standards;
  • Review of management review activities to include Labeling Standards as an agenda item;
  • Initiation of product hold procedures where safety or quality may be compromised;
  • Initiation of a product recall or product recall procedures where investigations show that there is a substantial safety and or quality risk to the released product;
  • Contacting stakeholders including customers regarding any confirmed or potential Labeling Standards concerns involving their product.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Corrective Action requirements in relation to their items.
You may wish to visit the Corrective Action and Preventative Action section of haccp.com for examples of best practice applications for this food safety and quality system element.

Labeling Standards Corrective Action and Preventative Action Key Points

  • The implementation of Corrective Action and Preventative Action provides confidence that your FS&Q Program is effectively implemented and that FS&Q criteria are being met;
  • Where deviations or variations are observed, Corrective Action and Preventative Actions must be facilitated to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • Corrective Action and Preventative Action of Labeling Standards must be facilitated as per relevant documented Policies, Procedures and Work Instructions;
  • Records of Corrective Action and Preventative Action must for Labeling Standards be maintained per relevant documented Policies, Procedures and Work Instructions;
  • Proper application of Corrective Action and Preventative Action for your Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • Poor application of Corrective Action and Preventative Action for your Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To review and confirm documented monitoring and corrective actions against documented parameters.

Verification

Verification: The act of reviewing, inspecting, testing, checking, auditing, or otherwise establishing and documenting whether items, processes, services, or documents conform to specified requirements.
Verification is the detailed review of all food safety and quality system elements to confirm that they are effectively developed, documented, implemented, monitored, and reviewed. All food safety and quality system elements, including documented policies, procedures, training, HACCP plans, and their operational applications must be verified on an ongoing scheduled basis. The verification process commonly includes a defined schedule for which verification activities are required, how often they are conducted, who is responsible, and detailed documented procedures for each nominated verification activity.
The general goal of an established verification process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
The following examples of verification activities may apply to Labeling Standards:

  • Review of the Labeling Standards policy;
  • Review of Labeling Standards development procedures;
  • Review of Labeling Standards implementation procedures and work instructions;
  • Review of Labeling Standards monitoring procedures;
  • Review of Labeling Standards monitoring records;
  • Review of Labeling Standards corrective and preventative action procedures;
  • Review of the Labeling Standards verification schedule;
  • Review of Labeling Standards verification procedures;
  • Review of the Labeling Standards validation schedule;
  • Review of Labeling Standards validation procedures;
  • Review of Labeling Standards training procedures;
  • Review of Labeling Standards performance since the last review and historically;
  • Analytical testing of product or process to ensure the effectiveness of Labeling Standards;
  • Inclusion of Labeling Standards as an agenda item within the Management Review Process.

A review of all Labeling requirements should be documented and implemented against the requirements of applicable legislative and industry standards, and internal and external specifications. This exercise aims to ensure compliance with the required Labeling standards and guidelines. Labeling reviews should be initiated:

  • At scheduled intervals;
  • Whenever there has been a change in the relevant legislation, industry standards, internal or external specifications;
  • Whenever allergens or ingredients containing allergens are introduced into the food business;
  • Whenever there has been a change in processing, handling, or storage, which may include changes to the composition of the foods being produced.
  • Whenever changes have been made to product specifications.

All of the Labeling requirements for the region or country in which the food products will be sold must be considered when reviewing Labeling.
If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Verification requirements in relation to their items.
You may wish to visit the Verification Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.

Labeling Standards Verification Key Points

  • Your verification program provides evidence that your FS&Q Controls have worked;
  • Labeling Standards programs must be verified to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • The verification of Labeling Standards must be facilitated as per relevant documented Policies, Procedures, and Work Instructions;
  • Nominated verification records for Labeling Standards must be maintained as per relevant documented Policies, Procedures, and Work Instructions;
  • A properly verified Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly verified Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

To confirm the documented monitoring or procedural limits.

Validation

Validation: The process of gathering evidence to provide a scientific basis for the documented act of demonstrating that a procedure, process, and activity will consistently lead to the expected results. It often includes the qualification of systems and equipment.
Validation is the provision of evidence to support the limits of control or acceptability for food safety or quality parameters nominated within systemic elements. Limits of control or acceptability are commonly included within documented food safety and quality systems elements such as procedures, HACCP plans, and specifications.
Common sources of validation include regulatory and legislative standards, finished product specifications and customer requirements, industry codes of practice and guidelines, verified and validated research, historical product, and process control outcomes, and analytical testing.
The general goal of an established validation process is to ensure any systemic non-conformance issues are identified and rectified within an appropriate time frame. When non-conformance issues are identified through the verification process, Corrective Actions and Preventative Actions should be implemented to ensure they do not impact the effectiveness of the food safety and quality system.
Validation activities are commonly defined within the verification schedules and procedures of established food safety and quality management systems.
The following examples may apply to validation of the limits of control or acceptability for Labeling Standards:

  • Confirmation of nominated food safety and food quality control limits for Labeling Standards. These limits may apply to regulatory, industry, customer, or finished product specifications;
  • Confirmation of analytical testing methods being used to confirm the effectiveness of Labeling Standards and ensure the accuracy of outcomes.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Validation requirements in relation to their items.
You may wish to visit the Validation Activities section of haccp.com for examples of best practice applications for this food safety and quality system element.

Labeling Standards Validation Key Points

  • Your validation program provides evidence that your FS&Q Controls will work;
  • Labeling Standards programs must be validated to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • The validation of Labeling Standards must be facilitated as per relevant documented Policies, Procedures, and Work Instructions;
  • Nominated validation records and supporting documentation for Labeling Standards must be maintained as per relevant documented Policies, Procedures, and Work Instructions;
  • A properly validated Labeling Standards program will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • A poorly validated Labeling Standards program will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

Skills, knowledge and competency requirements to facilitate development, documentation, implementation, monitoring, corrective action, verification and validation of every Food Safety and Quality System Element.

Skills and Knowledge

Skills and Knowledge: Skills and knowledge are attributes of human interactions commonly linked to competency within any specified job-related task.
Training and competency requirements for Labeling Standards must be ongoing, including regularly scheduled reviews to ensure the effectiveness of training and competency outcomes.
Team members who have defined responsibilities regarding Labeling Standards should have knowledge including:

  • Basic Labeling Standards requirements;
  • Positive outcomes of Labeling Standards;
  • Negative outcomes of a lack of Labeling Standards;
  • Current Labeling Standards procedures, methods, and techniques;
  • General operational, corporate, and social awareness regarding Labeling Standards;
  • Regulatory, industry, and customer requirements regarding Labeling Standards.

Team members who have defined responsibilities regarding Labeling Standards should have skills including:

  • Competency regarding basic Labeling Standards;
  • Effective application of current Labeling Standards procedures, methods, and techniques;
  • The basic development, documentation, and implementation of HACCP and Prerequisite Programs within the food industry sector.

Team members who have defined responsibilities regarding Labeling Standards should have access to resources including:

  • Labeling Standards training;
  • Labeling Standards associations and events;
  • Regulatory standards, industry and customer information and updates regarding Labeling Standards;
  • Incidents within the food industry sector regarding Labeling Standards;
  • Commitment to Labeling Standards by senior management;
  • Suitably qualified food industry professionals with verified experience in Labeling Standards;
  • Effective communication systems including email, internet, and phone through which Labeling Standards information can be sent and received within suitable timeframes.

If your food business supplies foodstuffs manufactured to a customer’s specifications, it is important to consider any specific Labeling Standards Training, Competency, and Resources requirements in relation to their items.
You may wish to visit the Training, Competency, and Resources section of haccp.com for examples of best practice applications for this food safety and quality system element.

Labeling Standards Training, Skills and Knowledge Key Points

  • Your Training, Skills, and Knowledge program ensures all participating personnel, visitors, and contracted have the required skills and knowledge to effectively facilitate the requirements of your FS&Q Program;
  • Training, Skills and Knowledge programs for Labeling Standards must be facilitated to meet relevant Regulatory, Industry, and Customer standards and requirements;
  • Training, Skills and Knowledge programs for Labeling Standards must be facilitated as per relevant documented Policies, Procedures, and Work Instructions;
  • Training, Skills, and Knowledge records for Labeling Standards must be maintained as per relevant documented Policies, Procedures, and Work Instructions;
  • Properly applied Training, Skills, and Knowledge programs for Labeling Standards will provide a strong framework for your business to maintain compliance with relevant Regulatory, Industry, and Customer standards and requirements;
  • Poorly applied Training, Skills, and Knowledge programs for Labeling Standards will not fully support your business and may contribute to significant non-compliance against Regulatory, Industry, and Customer standards and requirements.

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