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Labels and allergens

Updated

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The usual five apply, and confectionery carries more hidden allergens than almost anything else in this library.

The five

  • Statement of identity, which for a chocolate is a standardized name carrying the standard with it.
  • Net quantity, from the container and the fill.
  • Ingredients, in descending order by weight.
  • Allergens, declared as required.
  • Name and place of business of the responsible party.

Where the allergens hide

Milk in milk and white chocolate and in most caramels. Soy lecithin as an emulsifier in nearly all couverture. Nuts in praline, brittle and in whatever else ran on your equipment. Wheat in some fillings and in malt-based ingredients. Very few of those are obvious from the product name.

Cross-contact is the harder half

A nut brittle and a plain caramel made on the same surfaces share a problem, and buyers with a nut allergy read confectionery labels with particular care because the category is known for it. Whatever you say about shared equipment has to match how the equipment is actually run.

Which makes the cleaning record part of the label

A claim about a dedicated line or a thorough changeover is a claim about your operation, and the way to support it is a changeover record. Using a precautionary statement reflexively instead is easier and tells allergic buyers nothing useful.

Gelatin is worth declaring prominently

It is animal derived and a substantial number of buyers avoid it, and the ingredient list is where they will look. Saying so on the front of a pectin product is a selling point rather than a disclosure.

Order labels last

Net quantity depends on a settled jar, the ingredient list on a settled formulation and the allergen statement on a settled equipment plan. All three move during development.

Small packages have less room than you think

A gift-size jar or a small box still has to carry all five elements, and the panel area is genuinely tight. Designing the artwork around the largest format and shrinking it for the smallest is how required text ends up illegible, so work the small one out first.

References

21 CFR 101, Food Labeling, which carries the general requirements that apply where there is no standard of identity: the statement of identity, net quantity, ingredient list, allergen declaration and the name and place of business of the responsible party. law.cornell.edu
21 CFR 163.130, Milk chocolate: not less than 10 percent by weight of chocolate liquor, not less than 3.39 percent milkfat and not less than 12 percent total milk solids. law.cornell.edu
Written from federal regulation and the published physical chemistry of sugar and cocoa butter, not from a laboratory. The chocolate standards of identity are specific and the sugar confectionery names are not, which is the main thing to carry away. Anything here is a starting point for a conversation with your state department of agriculture, not a determination that you comply.