Fafai Workshop on MODEL LABELING

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Fafai WorkshoponMODEL LABELING

• Flavorings
• and
• related products

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25th August 2007

• Vamsi Seminar hall,
• Iskcon, Juhu, Mumbai

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presentation

• J.C. Kathrani
• Ravi Mehra

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A Collective Endeavour to frame model
label for flavor and related products of
flavor industry.
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GSR 491 (E)

• It amends the Rule 32 (Labeling)
• It comes into force wef 20.2.2008

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What are the variations in our labeling?
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Whether the following terminology find any
reference / place in PFA act ?

• Free From alcohol
• Dilutants
• Artificial flavor emulsion
• Nature Identical Flavor Emulsions
• Pictures of Fruits on labels
• Multiple office Addresses
• Placement of the Vegetarian sign away from the
  product name

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Rule 32with GSR 491 (E )expects what ?
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Before we understand the labelingsomeImportant
definitions
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Flavoring Agents Rule 63 ABC
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Flavor Emulsions

• No definition under PFA

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Consumer

• Consumer means persons and families purchasing
  and receiving food in order to meet their
  personal needs.

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Food
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Prepacked Food

• (t) prepackaged means packaged or made up in
  advance in a container, ready for offer to the
  consumer.

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Date of manufacture

• Means the date on which the food becomes the
  product as described.

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Date of packaging

• Means the date on which the food is placed in the
  immediate container in which it will be
  ultimately sold.

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Best Before

• Means the date which signifies the end of the
  period under any stated storage conditions during
  which the product will remain fully marketable
  and will retain any specific qualities for which
  tacit or express claims have been made.
• However, beyond the date the food may still be
  perfectly satisfactory

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Use by date / recommended last consumption date
/ Expiry Date

• Means the date which signifies the end of the
  estimated period under any stated storage
  conditions, after which product probably will not
  have the quality attributes normally expected by
  the consumers and the food shall not be
  marketable.

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Food Ingredient

• Means any substance, including a food additive,
  used in the manufacture or preparation of a food
  and present in the final product although
  possibly in a modified form

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Label and labeling

• (q) label means a display of written, graphic,
  perforated, stamped, tag, brand, mark, pictorial
  or other descriptive matter, printed, stenciled,
  marked, embossed or impressed on, or attached to,
  a container, cover, lid or crown of any food
  package
• (r) labelling including any written, printed or
  graphic matter that is present on the label
  accompanying the food.

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Lot Number or Code Numberor batch number

• (s) Lot number or Code number or batch
  number means the number either in numericals or
  alphabets or in combination, representing the Lot
  number or code number or batch number being
  preceded by the words Lot No or Lot or code
  number or Code or Batch No or Batch or any
  distinguishing prefix by which the food can be
  traced in manufacture and identified in
  distribution.

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Principal Display Panel

• (u) principal display panel means that part of
  a label which is intended or is likely to be
  displayed, and presented or shown or examined by
  the customer under normal and customary
  conditions of display, sale or purchase of the
  commodity contained in the package

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Labeling RequirementsFor Flavoring compounds
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Labeling RequirementsFor Flavoring compounds

• Although, no more specifically specified, still,
  we shall carry-
• The Name, Trade Name, Description of the Flavor.

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Vegetarian / Non Vegetarian

• a) a declaration to this effect shall be made
  by a symbol and colour code so stipulated for
  this purpose to indicate that the product is
  Vegetarian Food. The Symbol shall consist of a
  green color filled circle, having a diameter not
  less than the minimum size specified in the Table
  given below, inside the square with green outline
  having side double the diameter of the circle, as
  indicated in clause (17) of sub-rule (ZZZ) or
  rule 42

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Non Vegetarian foodRule 42 ZZZ clause 16

• a) a declaration to this effect shall be made by
  a symbol and colour code so stipulated for this
  purpose to indicate that the product is
  Non-Vegetarian Food. They symbol shall consist
  of a brown color filled circle having a diameter
  not less than the minimum size specified in the
  Table given below, inside the square with brown
  outline having side double the diameter of the
  circle, as indicated in clause (16) of sub-rule
  (ZZZ) of rule 42

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Rule 42 ZZZ clause 16 / 17

• The Veg. / Non Veg. Symbol would be on
• the principal display panel
• just close in proximity to name
• or brand name of the food

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Table for size

• S.No. Area of principal
• display panel Min.
  size of diameter in mm
• 1. Up to 100 cms square 3
• 2. Above 100 cms square
• upto 500 cms square 4
• 3. Above 500 cms square
• upto 2500 cms
  6

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Ingredients Rule 32 three paras prior to (
c ) ( i )

• Provided also that for declaration of flavours on
  the label the class of flavours namely, Natural
  Flavours and Natural Flavouring Substances or
  Natural-Identical Flavouring Substances or
  Artificial Flavouring Substances as the case may
  be, shall be declared on the label.

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Ingredients to Flavorings

• Solvents / Carriers, Water, Emulsifiers,
  Stabilizers, Class II Preservatives, Anti
  Oxidants.
• If caffeine is added it shall be declared on the
  label as per 42 ZZZ - 18

Contains caffeine
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Net Contents, Weight , Volume
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W M Act 1977 rule (13 9 (7) (a)

• Symbols of International system of units
• Kilogram Kg
• Gram g.
• Litre l
• Milli litre ml.

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Lot / Code / Batch Identification

• (e) Lot/Code / Batch identification. -
• A batch number or code number or lot number which
  is a mark of identification by which the food can
  be traced in the manufacture and identified in
  the distribution, shall be given on the label.
• (f) Date of manufacture or packing. -
• The date, month and year in which the commodity
  is manufactured, packed or pre-packed,

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Date of manufacture or packing

• (f) Date of manufacture or packing. -
• The date, month and year in which the commodity
  is manufactured, packed or pre-packed, shall be
  given on the label
• Provided that the month and the year of
  manufacture, packing or pre-packing shall be
  given if the Best Before Date of the products
  is more than three months
• Provided further that in case any package
  contains commodity which has a short shelf life
  of less than three months, the date, month and
  year in which the commodity is manufactured or
  prepared or prepacked shall be mentioned on the
  label.

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Best Before under storage conditions

• 5(i) the month and year in capital letters up to
  which the product is best for consumption, in
  the following manner, namely
• Best Before-------- Months and Year
• or
• Best Before --------- Months From Packaging
• or
• Best Before --------- Months From Manufacture
• or
• Best Before upto--------- month and year For
  the period or upto and
• Best Before within-------- Months inclusive of
• From the Date of Packaging / Manufacture 1 st
  September 2001 (Note blank be filled up)

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MRP

• Not included in PFA amendment
• Standards of Weights Measures (Packaged
  Commodities) Rules, 1977 to be refered.
• Rule 2 read with Rule 6 (1) ( f ) applies

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MRP defination - Rule 2 ( r )

• ( r ) retail sale price means the maximum
  price at which the commodity in packaged form may
  be sold to the ultimate consumer and where such
  price mentioned on the package, there shall be
  printed on the package, the words
• Maximum or Maxi. Retail price inclusive of all
  taxes.
• Or
• MRP. Rs. Inclusive of all taxes.

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Address of Manufacturer

• (C) (i) the name and complete address of the
  manufacturer and the manufacturing unit, if these
  are located at different places and in case the
  manufacturer is not the packer or bottler, the
  name and complete address of the packing or
  bottling unit as the case may be

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Address of Mfr. / Packer

• (ii) where an article of food is manufactured or
  packed or bottled by a person or a company under
  the written authority of some other manufacturer
  or company, under his or its brand name, the
  label shall carry the name and complete address
  of the manufacturing or packing or bottling unit
  as the case may be, and also the name and
  complete address of the manufacturer to the
  company for and on whose behalf it is
  manufactured or packed or bottled

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Address of the Importer

• (iii) where an article of food is imported into
  India, the package of food shall also carry the
  name and complete address of the importer in india

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Address

• Provided that where any food article manufactured
  outside India is packed or bottled in India, the
  package containing the such food article shall
  also bear on the label, the name of the country
  of origin of the food article and the name and
  complete address of the importer and the premises
  of the packing or bottling in India.

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Country of Originrule ( v ) ( j)

• Applicable to Imported Flavors, and those that
  are manufactured outside India and packed in
  India.
• Not Applicable for those flavors that are
  indigenous.
• Recommended by Fafai For all the food products
  manufactured in India for national, Export,
  Import market.

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Instructions to Use(v) (k)

• Instructions to use, including reconstitution,
  where applicable, shall be included on the label,
  if necessary, to ensure correct utilization of
  the food

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Exemptions

• Batch Number, List of Ingredients, Code No. Lot
  No, Best Before Date exempted to labels that are
  just 10 cm square sized.
• However the wholesale packs have to mention all
  the requirement.

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Principal display panel, its area, size and
letter, etc. Principal panel means that part
of a label which is intended or is likely to be
displayed, presented or shown or examined by the
customer under n9rmal and customary iitions of
display, sale or purchase of the commodity of
food contained in theage.
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(2) The area of the principal display panel
shall not be less than -(a) in the case of a
rectangular container, forty percent of the
product of height and width of the panel of such
container having the largest area(b) in case of
cylindrical or nearly cylindrical, round or
nearly round, oval or nearly oval container,
twenty percent of the product of the height and
average circumference of such container or
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(c) in the case of container of any other shape,
twenty percent of the total surface area of the
container except where there is label, securely
affixed to the container, such label shall give a
surface area of not less than ten percent of the
total surface area of the container.
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(3) In computing the area of the principal
display panel the tops, bottoms. flanges at top
and bottoms of cans, and shoulders and necks of
bottles or jars shall be excluded.
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.(4) In the case of package having a capacity
of five cubic centimeters or less, the principal
display panel may be card or tape affixed firmly
to the package or container and bearing the
required information under these rules..
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(5) The height of any numeral in the
declaration required under these rules, on the
principal display panel shall not be less than
-(i) as shown in Table - I below if the net
quantity is declared in terms of weight or
volume.TABLE -1
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Culinary Flavorings

• These are within the definitions of
• Consumer prepackaged foods
• Hence 491 (a) and (b) applies.

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Endof part one
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NowRule 40amendments
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GSR 491 - Rule 40 ( iii )

• (iii) Any food product which contains only fruit
  flavors whether natural flavors and natural
  flavoring substances or nature identical
  flavoring substances or artificial flavoring
  substances as singe or in combination, shall not
  be described as a fruit product and the word
  FRUIT shall not be used in describing such a
  product and such product shall not be sold with a
  label which carries the picture or word of any
  fruit. However, the product may contain a
  declaration as contains (name of the fruit)
  flavor

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Fafais Objection to Rule 40(iii)

• FRUIT CONTENTS includes Fruit Extracts and Oils.
• Products with Natural ingredient should not be
  equated as Artificial
• The said rule MUST be reviewed, modified and
  until then deferred.

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Fafais Further Objection to Rule 40(iii)

• If the word FRUIT has not to be used then how
  to label the artificial flavors of the following
• Dew Fruit
• Grape fruit
• Passion Fruit
• Jackfruit
• And so on

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Representationon Fafais objection to rule
40of GSR 491 (E)can be seen in your
Folders.Suggestions welcome
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Flavor Emulsions and pastes

• Refer to
• Rule 28
• Rule 29
• Rule 30
• Rule 42 ZZZ (13)
• Rule 60, 61 B, 63 ABC, 64A, 72B, 72C
• Rule 83, Appendix C table 3 (6)
• Appendix C, Rule 5, INS

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Flavour Emulsions to contain

• Flavor,
• Food Color (Rule 28)
• 100 ppm upon dilution in final product except
  SSY that is 50 ppm
• Benzioc Acid and salt as per GMP
• Emulsifier / stabilizer as per GMP
• Anti Oxidants max. 0.01 percent
• water, Solvent

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Extra Labeling requirementfor emulsions

• Flavor emulsions for Carbonated / non carbonated
  beverages only.
• Instructions to dilute for final product to be
  provided.

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I (ZZZ) (13) Every container or package of
flavor emulsion and flavor paste meant for use in
carbonated on non-carbonated beverages shall
carry the following declaration, in addition to
the instructions for dilution, namely
(FLAVOUR EMULSION AND FLAVOUR PASTE FOR USE lN
\ CARBONATED OR NON-CARBONATED BEVERAGES ONLy)
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Frequent Issues

• Free From alcohol
• Dilutants
• Artificial flavor emulsion
• Nature Identical Flavor Emulsions
• Pictures of Fruits on labels
• Multiple office Addresses
• Vegetarian sign away from the product name
• Are flavors proprietary Foods ? Rule 37 A
• What happens to those products that are
  manufactured prior to the last date with three
  years of best before
• date ?

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Minimum Punishment

• Six Months Jail
• Cases for simple violations linger on for Years
• Most cases for simple violations only.

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Grateful to

• Tushar Shah, regional secretary, West, fafai.
• Satish Hinduja, Kamlesh Hinduja
• Bansi bhai, Hussain Mamuwala,
• Murthy / Fafai Office.

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Special Thanks

• Dr. Ramesh Mantri
• Shyam Prabhu
• Gopal Talreja, M/s General Imports for hosting
  the Lunch.
• Iskcon Management

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Thanks
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