The FDA has recently issued new regulations that involve the radical change of the nutritional tables of food products on sale in the United States of America
To import specialty foods into the US, it is necessary to change or implement the new nutritional tables and bring the labels into compliance starting from 26 July 2018
New FDA labels for the US
The new FDA regulation on the nutritional values tables [now called Nutrition Label] involves changes in substance and format
In the new labels, the size and position of the texts and borders change. Some entries [for example, calories from fat] have been eliminated, and new ones added [for example, added sugars]
Food products imported into and sold in the US must comply with the changes as of July 26, 2018 [July 26, 2019, if the manufacturer sells less than $ 10 million a year of specialty foods]
Contact us to comply with the label requirements concerning the products you wish to import into the United States. Call our Rimini office at 0541-709073
The US new legislation on nutritional tables involves substantial changes, and, as a result, it is necessary to complete a new analysis of the ingredients for compliance with the FDA requirements. Below are the most significant changes introduced by the new regulations:
- Change to the Serving Sizes [and, consequently, the Serving per Container as well];
- Change to the daily quantities and, consequently, the percentages of each ingredient in the nutritional value tables require updating;
- Introduction of a double column nutritional table for those food specialties that can also be consumed in a single meal [and not only in portions];
- The Calories from Fat entry has been eliminated;
- The Vitamin A and C entries have been eliminated;
- It is mandatory to provide Potassium and Vitamin D values;
- Among the most significant changes, however, we point out the requirement to provide the "Added Sugars" values and the new definition of the "Dietary Fiber". The FDA is about to issue further explanatory regulations regarding these two elements.
Date for compliance with the nutritional value tables for the United States: extension for small and medium-sized companies
The date by which companies must comply with the tables and nutritional values of food products to be exported to the United States has been set for January 1, 2020
However, companies that invoice less than 10 million dollars a year from the sale of food products have until January 1, 2021 to comply with the law. We point out that in order to ascertain the size of the annual turnover, the FDA requires a copy of the latest tax return or balance sheet.
It is not clear whether a copy in Italian is enough or if an English version is needed, perhaps authenticated by a notary and accompanied by an apostille. Likewise, it is still unclear whether an accompanying statement from an accountant is also needed. In addition, it should be borne in mind that if a company sells food and other products, it will have to detail the item "Sales Revenues" in order to highlight that the sales of food specialties amount to less than 10 million dollars.
Regardless, a copy of the tax return or balance sheet must be attached to the United States import customs file. Consequently, all company data would become known to the shipper, the Italian customs declarant, the US custom broker, the Italian customs officers and the US customs inspectors, as well as the FDA officials in the US, and ultimately, the final recipient of the goods. We emphasize the fact that each of these actors has extensive contacts with all your competitors in Italy and the US.
Our recommendation? Forget the extension for compliance with the new requirements for the nutritional value tables, and aim to have all changes made by January 1, 2020 for import into the US
FDA ExportUSA consultancy service for Food Products and Food Supplements
Revision of labels, creation of nutritional labels, FDA registration, FDA Agent service
ExportUSA, among its FDA consultancy services for the importation of food into the United States, can assist foreign companies in bringing the new nutritional value tables up to standard.
In closing, we would like to point out that the FDA has also updated the rules that govern the tables and nutritional values of food supplements, albeit in a less drastic way than in the case of food specialties.