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What are the labeling rules governing principle display panel (PDP) photos?

August 20, 2007
Question 

Is it required to label a photo of our product as "serving suggestion" on the PDP? What are the rules governing this?

 

Answer 

There are no federal rules specifically governing the use of "serving suggestion" on the principle display panel (PDP). However, section 403(a)(1) of the Federal Food, Drug, and Cosmetic Act deems a food misbranded "if its labeling false or misleading in any particular... ." As you likely know, it is permissible to "stage" a food picture to present the food in the best possible manner. Including in the picture one or more foods that are not also in the package, on the other hand, could be considered misleading to consumers and cause the package to run afoul of Sec. 403(a)(1). Of course, the exact composition of the picture, combined with the label language, size of the package, etc. would all be considered when determining if the labeling is misleading. To avoid this problem, most manufacturers state "serving suggestion" beside any picture of the food on the label that does not exactly match the food that is in the package. Such labeling also eliminates the potential for customer confusion and potential disappointment in the product after purchase, which could lead to complaints to state authorities. Please contact us directly if you need assistance on your specific product.