FSIS Issues Temporary Guidance for HVP Labeling

WASHINGTONIn the wake of recent recalls involving hydrolyzed vegetable protein (HVP), USDAs FSIS issued temporary guidance for product formulations and labeling of products containing HVP, or a seasoning containing HVP.

The revisions are likely to cause existing labels to be out of compliance, and consequently, establishments may need to obtain temporary approval for continued use of these labels. To obtain temporary approval, companies will need to submit a request to FSIS Labeling and Program Delivery Division. These requests will be expedited and should be clearly marked with a justification, e.g., HVP temporary label submission.

An establishment seeking a temporary approval should follow the instructions highlighted on the FSIS Web site at www.fsis.usda.gov/Regulations_&_Policies/Requesting_Temporary_Label_Approvals/index.asp.

Temporary approval can be granted for any product if the HVP is removed. If the HVP is replaced with another ingredient, there cannot be any allergen concerns. For example, if a hydrolyzed soy protein is added to the product, soy should already need to be listed in the ingredient statement. In situations where negative claims or nutrient content claims appear on labeling, it is critical to stipulate that all claims will continue to be met, or provide information to support that claims remain correct.

In some cases, a blanket temporary approval is the best approach. Requests should include an example of the product formulation, the corresponding label, a list of all the prior approval numbers of the products affected and an inventory of each label. The label application needs to clearly state the reason for temporary approval as noted in the document.