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Issue list for your consultant
Label findings
Larkspur, front and back panel
Front panel says “High in fiber”. 3 g per reference amount is 11% of the 28 g Daily Value; the claim needs 20% or more.
21 CFR 101.54(b)(1); 101.9(c)(9)
Reword to “good source” under 101.54(c)(1), or reformulate?
Ingredient list puts sesame seeds ahead of wheat flour, which weighs more in the formula.
21 CFR 101.4(a)(1)
Confirm the order against the current batch formula.
Back panel names the firm but gives no street address, city, State or ZIP code.
21 CFR 101.5(d)
Is our street address in a current directory, so it may be left off?
“Larkspur” is the only name on the front: no statement of identity.
21 CFR 101.3(a), (b)
Is “seeded crackers” the right common or usual name?