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What goes wrong

A claim you cannot support

Updated

On this page7
The most common labeling failure here is not a false claim. It is a true one the maker cannot demonstrate, which is the same position when somebody asks.

Extra virgin is the sharpest example

It corresponds to a grade with a free fatty acid limit and a sensory panel behind it. If you bottle somebody else’s oil, the claim is theirs and you are repeating it, so you need it in writing against the lot you bought. A general assurance from a supplier is not documentation.

Claims about process

Cold pressed, first press, stone ground and similar describe how the oil was made, which is information you do not hold unless the supplier gave it to you. Repeating what a distributor said on the phone is the version of this that collapses first.

Claims about origin

A country or region on a label is a claim about where the oil came from, not where it was bottled, and the two are routinely different in this category. If the oil was blended from more than one origin, saying so is the only honest option.

Claims that contradict each other

Unfiltered sits awkwardly next to a grade statement whose standard requires freedom from sediment. Raw sits awkwardly next to a stable, clear product. Labels get assembled from appealing words and the combination sometimes makes a claim nobody intended.

The test to apply before printing

For every claim on the label, ask what you would hand somebody who asked you to prove it. If the answer is a document with a lot number on it, the claim is fine. If the answer is a conversation you remember, take the claim off.

Keep the documents with the lot, not in an inbox

A supplier certificate that exists somewhere in an email thread is not retrievable at the moment it matters. File it against the lot number in the same place the batch log lives, so that proving a claim is a lookup rather than an archaeology exercise.

References

United States Department of Agriculture, Agricultural Marketing Service. United States Standards for Grades of Olive Oil and Olive-Pomace Oil, 7 CFR 52.1531 to 52.1542, published at 75 FR 22363 and effective October 25, 2010. Voluntary standards issued under the Agricultural Marketing Act of 1946. ams.usda.gov
United States Food and Drug Administration. Compliance Policy Guide Sec. 525.825, Vinegar, Definitions: “No standards of identity for vinegar have been established under the Federal Food, Drug, and Cosmetic Act,” and each listed variety “should contain 4 grams of acetic acid per 100 mL.” fda.gov
Written from federal regulation, voluntary USDA grade standards, FDA labeling policy and published extension guidance, not from a laboratory. The infused-oil pages describe a real botulism hazard and are a starting point for a conversation with your state department of agriculture and a process authority, not a determination that any method you use is safe.