July 16, 2019

July 16, 2019

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July 15, 2019

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FSIS Issues Guideline on Labeling of “Kit” Products with Meat/Poultry Component

On July 9, 2019, USDA’s Food Safety and Inspection Service (FSIS) issued a notice of availability and a request for comment on a new guideline for kit products that contain a meat or poultry products.  84 FR 32705.  The guideline is available here. Specifically, the guideline addresses the circumstances in which the assembly of a “kit product” that contains meat or poultry needs to be done under FSIS inspection and the labeling required for these products. This is the first time the Agency has addressed this topic via formal guidance.

A “kit product” consists of individually-packaged food components sold together as a single unit, such as pizzas, salads, fajitas, wraps, meals, etc. that contain a meat or poultry component.  FSIS guidelines state that the act of assembling a kit product that contains meat or poultry does not need to be done under FSIS inspection if the following conditions are met:

  • The meat or poultry component is prepared and separately packaged under FSIS inspection and labeled with all required features;

  • The outer kit label identifies all of the individual components in the kit; and

  • The outer kit label clearly identifies the product as a single unit or “kit,” such as “Chicken BBQ Dinner Kit” and “Beef Lasagna Meal.”

Comments on the guideline are due by September 9, 2019.  In its notice, FSIS states that once it assesses comments, the Agency will issue instructions to the Office of Field Operations to clarify what products constitute kits that should no longer be under inspection.

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Keller and Heckman offers global food and drug services to its clients. Our comprehensive and extensive food and drug practice is one of the largest in the world. We promote, protect, and defend products made by the spectrum of industries regulated by the U.S. Food and Drug Administration (FDA), the European Commission and Member States authorities in the European Union (EU) and similar authorities throughout the world. The products we help get to market include foods, pharmaceuticals, medical devices, veterinary products, dietary supplements, and cosmetics. In addition...

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