January 2, 2018

No Regulations for Love and Vice Versa

By Bryan K. Wheelock, Principal

warning letter from FDA back in September 2017 complained about a bakery including “love” in its list of ingredients for its bread:

  1. Your Nashoba Granola and Whole Wheat Bread (wholesale and retail) products are misbranded within the meaning of section 403(i)(2) of the Act [21 U.S.C. § 343(i)(2)] because they are fabricated from two or more ingredients, but the labels fail to bear a complete list of all the ingredients by common or usual name in descending order of predominance by weight as well as all sub-ingredients, as required by 21 CFR 101.4. For example,

The letter goes on,

  • Your Nashoba Granola label lists ingredient “Love”. Ingredients required to be declared on the label or labeling of food must be listed by their common or usual name [21 CFR 101.4(a)(1). “Love” is not a common or usual name of an ingredient, and is considered to be intervening material because it is not part of the common or usual name of the ingredient.

While regulation is a necessary evil, ridiculous incidents such as this are important reminder that it is an evil.