USDA Labeling Special Claims
USDA Special Claims Labeling can be a beast. Determining what can and can not be put on a label, what can and can not be generically approved at the plant and how to go about submitting for approval can be a daunting task. A task so daunting, many people 10-15 years ago would pay good money to have a third-party consulting company get their labels approved for them. Nowadays, there is no need to waste more money that you need to when all it really takes is a little bit of research and time. There are excellent resources available to you via the USDA website, which granted, can be a bit of a challenge to come by. You can find the big, scary, federal regulation guide here. I'll be the first to admit that is a daunting document. When I did my first label, I was working off of previously approved labels and only modifying a few things. I found that document as I was looking for an answer to a question and nearly panicked, "How is anyone supposed to know all of this!" I quickly figured out that, frankly, you aren't. The document is there for detailed issues, and thought it does contain some great tips and tricks, I couldn't believe there wasn't another way. Don't get me wrong, the information is there, but it is also available in a much, much more digestible format.
The first of two documents to help you make sense of the federal regulations is the FSIS Compliance Guideline for Label Approval. This document outlines many of the regulations, and has appendices which list what claims can be generically approved (in plant) and what claims need to be approved by FSIS Labeling in Washington D.C. Some of the items you find on there may surprise you. For instance, use of a State Outline is not generically approved, however some states programs (such as Wisconsin Cheese) can be allowed, depending on the program. Once you have determined your claim is a Special Claim that needs D.C. approval, the FSIS Guidelines for Documents Needed to Substantiate Animal Raising Claims has examples of documentation that can be used to support your claims when submitting your label for approval.
Once you've got all your documentation together and you need to get your label mocked up. We can do this in house for simple labels, or you can use an outside label printer for more complex and full color labels. These items will go on your application to FSIS Labeling through the Labeling Submission and Approval System (LSAS). This can be done on your own, and if you do more power to you! However, we do always recommend you send your documentation and mock label to us for submission, so we can limit corrections needed to be made after submission.
Now the last question is what sort of time frame do I need to get a label approved? There are a few factors that play in to this, but as a general rule no less than 90 days. I usually estimate, for a simple claim and a in house label, 1 week preparation of the application (plus what ever time it takes you to get additional documentation needed.) Having a label mocked up by an outside label printer can take up to a month. From there, it is submitted to LSAS, and sits in the queue for around 45 days. If any changes are required by LSAS before approval, 1 week to make changes and adjustments to your application and up to another 45 days for final approval. Once that's done you can have the printing company print your labels and send them to us, or have us start utilizing the newly approved label.
Now that you're ready to start, feel free to give us a call! We're happy to help with all of the above, and provide you with our professional insight. Fees start at $100 but will vary on an individual basis.