4. Labeling Requirements

General Foods
USA

This section provides information on labeling requirements and the label approval process.

4.1 Mandatory Labeling Parameters

General Food

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Category

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Product

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4.2 Languages

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4.3 Mandatory Information on Stickers

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4.4 Product Legal Name

Product

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4.5 Product-specific Labeling Statements

Category

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Product

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4.6 Authority Approval

General Food

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Category

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Product

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4.7 Additional Notes on Labeling

Regulatory overview of country of origin requirements for label declaration

According to 21 CFR Part 101 Subpart A on the general provisions for food labeling [1], the manufacturer, packer, or distributor's name and place of business shall be stated on the label.

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Figure 1. Excerpt from 21 CFR 101.5

 

While the above clause does not specifically prescribe the country of origin (COO) requirement, it is the 19 CFR 134 on Country of Origin marking that precisely addresses the requirement for labeling the country of origin [2]. It states that, unless an exemption applies, every article of foreign origin, or its immediate container, must be marked permanently, legibly, and in a conspicuous place so as to permit the ultimate purchaser in the U.S. to know the English name of the country of origin of the article.

Figure 2a. Excerpt from 19 CFR 134.1

 

Figure 2b. Excerpt from 19 CFR 134.11

 

Exemptions to the COO marking requirements are given to articles that meet the conditions shown in Figure 3. More details on the types of articles that can be exempted are available in the “Informed Compliance Publication: Marking of Country of Origin on US Imports” [3].

Figure 3. Excerpt from 19 CFR 134.32

 

     Notes: 

     Point (n) refers to imported articles not over $800 in value, as bona-fide gifts, etc.

     NAFTA or USMCA country refers to the territory of the United States, Canada, or Mexico

Regarding the naming of country of origin, 19 CFR 134.45 states that it shall be the full English name of the country of origin with allowance for abbreviations/variant spellings that would unmistakably indicate the name of a country.

Figure 4. Excerpt from 19 CFR 134.45

 

=> Except when specifically exempted, every article of foreign origin, or its immediate container, must indicate the English name of the country of origin of the article. Abbreviations/variant spellings are possible but must unmistakably indicate the name of a country.

Conclusion

In the USA, unless exempted (see Figure 3), it is mandatory to declare the country of origin on the product label by stating the full English name of the country. The use of abbreviations or variant spelling is allowed as long as they would unmistakably indicate the name of a country.

4.8 References

1. Code of Federal Regulations, Title 21 (Food and Drugs), Chapter 1 (Food and Drug Administration), Subchapter B (Food for Human Consumption), Part 101 Subpart A on General provisions for food labeling

https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A

2. Code of Federal Regulations, Title 19 (Custom Duties), Chapter 1 (US Custom and Border Protection), Part 134 on Country of Origin marking 

https://www.ecfr.gov/current/title-19/chapter-I/part-134

3. Informed Compliance Publication: Marking of Country of Origin on US Imports

https://www.cbp.gov/sites/default/files/assets/documents/2020-Jul/ICPMarking-of-COO-onUS-Imports.pdf