The FDA cited Vanlaw Food Products Inc. after three recalls over the course of 2022. This warning letter highlights the labeling violations and the implications of those violations. Far too often we see misbranding issues when it comes to allergen labeling, this can be problematic for companies not only from a logistical standpoint but from consumer trust as well. Let’s dive into the warning letter!
In the summer of 2022 Vanlaw had to recall Whole Foods 365 Organic Creamy Caesar Dressing after they were notified by the customer that the back label was a label for the company’s ranch dressing which did not contain the allergens wheat and soy. The product was thus misbranded and was voluntarily recalled. The company responded to the FDA stating that relabeling of product had occurred, but the process was not verified or monitored in process but reiterated that it was an isolated incident.
A few weeks later the recall was expanded when additional lots were discovered to have been mislabeled and lacked the proper allergen statement for the packaged item. It was also discovered that another lot of Caesar dressing from earlier in the spring was also mislabeled with a blue cheese dressing label that again failed to label wheat and soy.
The company did not identify and implement preventive controls to provide assurances that any hazard requiring a preventive control (i.e., undeclared allergens) will be significantly minimized or prevented and the food manufactured, processed packed or held by your facility will not be adulterated under section 402 or misbranded under section 403(w) of the Act, as required by 21 CFR 117.135(a)(1) and (c)(2).
Why can this create an issue for a company?
The lack of control can lead to both voluntary and federally required recalls which can be very costly. If a company cannot ensure that the product is packaged properly then this will introduce a high level of risk for the consumer and create massive hurdles for the company.
If a company is manufacturing a product with any of the 9 major allergens, they are liable from receiving through the end of packaging. They must implement processes and procedures to avoid allergen misbranding.
Be sure that your team is trained, aware, and documenting the process. The situation that occurred with Vanlaw Foods is avoidable when a company has an elaborate food safety plan that is properly implemented.
To read the letter in full, click HERE.
If anything in the letter sounds familiar from your facility, or you would just like to be better prepared for your own FDA inspection when the time comes, let us know. In addition to label compliance reviews, we do facility audits and consulting on following cGMPs. Contact us today to discuss your needs and get a free quote.