When it comes to transformation, small changes are crucial to the overall aesthetic. But tweaks to the Nutrition Facts Label beg the question: How much will these updates affect product packages?
The answer is, potentially, a lot.
“The new information that the Food and Drug Administration is now requiring doesn’t fit onto the size of small packages such as snack cakes or brownies,” said Lee Sanders, senior vice-president of government relations and public affairs and corporate secretary, American Bakers Association (A.B.A.), noting that during a survey, the A.B.A. found close to 1,000 products that fall into this category.
“It’s not just baked products, though,” she said. “There are other sectors having the same issue.”
One issue within the regulation that determines size is the dual column rule because it will force food manufacturers to print two labels onto the package. Dual column labeling is only required if products are larger than a single serving but could be consumed in one sitting or multiple sittings. This is based on package size relative to the serving size, or Reference Amounts Customarily Consumed (RACC), which is mostly derived from Nationwide Food Consumption Surveys conducted by the U.S. Department of Agriculture. The F.D.A. gave an example of a 24-oz bottle of soda or a pint of ice cream.
“If the package size falls into the magic window of 200% to 300% of the RACC, then dual column labeling is going to be required — labeled as a serving and also as a package,” said Melissa Grzybowski, U.S. regulatory and nutrition specialist, Food Consulting Co. “I think we’ll find that some manufacturers are going to go to a smaller single-serving package, and some will avoid that and just label it as a dual column.”
A new label is costly enough, but the redesign of an entire package is an even greater expense. Ms. Sanders suggested that it could run anywhere from around $600 per stock-keeping unit to $4,000, depending on the product.
“Certainly, the design and plating for the changes will create cost,” said Gunther Brinkman, vice-president, contract manufacturing, Ideal Snacks Corp. “I suspect a number of companies will hold back other artwork changes now that the Nutrition Facts Panel and front-of-pack Vending Machine (Labeling Requirements) change dates look to have been harmonized, however, so the actual marginal cost may be lower than it looks at first glance.”
The A.B.A. has met with the F.D.A. several times, even bringing in sample packaging as a demonstration, to emphasize the issue of small packaging for bakers and others to urge a timely solution. Ms. Sanders said the F.D.A. said it plans to come out with guidance on that issue in the form of a Q.&A. document.