Review beverage labels for the US market

ArcheSync supports label review for beverages within its FDA food-labeling scope. The appropriate checks depend on the product category and the label information available. A conventional beverage and a liquid dietary supplement may need different treatment, so resolve an uncertain classification before relying on a category-specific review.

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Demonstration render of a fictional blood orange sparkling juice drink can. — Demonstration artwork. Fictional brand, not a customer label.

What a beverage review covers.

Statement of identity
The name of the drink; terms such as "juice drink" signal a diluted juice beverage.
21 CFR 101.3; 102.33
Percent juice declaration
Required when the label names or depicts juice, near the top of the information panel.
21 CFR 101.30
Nutrition Facts
Full or simplified format, and the "Not a significant source of" statement when it is required.
21 CFR 101.9(f)
Net contents
Fluid ounces for liquids, in the bottom 30% of the principal display panel.
21 CFR 101.7(b)(2), (f)
Ingredient list
Descending order of predominance by weight.
21 CFR 101.4(a)(1)
Beverage or supplement
A product represented as a conventional beverage is reviewed as food.
21 U.S.C. 321(ff)(2)

An annotated example.

The demonstration can declares "Contains 20% juice" at the bottom of the information panel instead of near the top.

Flat label artwork for a fictional blood orange sparkling juice drink can with a simplified Nutrition Facts panel. — Demonstration artwork. Fictional brand, not a customer label.

Evidence: "CONTAINS 20% JUICE" is printed at the bottom of the information panel, below the Nutrition Facts, ingredients and distributor line.
Why: 21 CFR 101.30(e)(1) places the percent-juice statement near the top of the information panel, with no other printed label information above it except the brand name, product name, logo or universal product code.
Next step: Move "CONTAINS 20% JUICE" above the Nutrition Facts.

sparkling_can_label.pdf

Food, beverage. Illustrative sample

Uploaded5 elements extractedFindings with clauses

No issueStatement of identity: sparkling juice drink21 CFR 101.3
No issueNet quantity in fluid ounces, bottom 30% of the panel21 CFR 101.7(b)(2), (f)
No issueSimplified Nutrition Facts with "Not a significant source of" statement21 CFR 101.9(f)(4)
No issueDistributor name and place of business21 CFR 101.5
Flag"Contains 20% juice" printed below the Nutrition Facts, not near the top of the information panel21 CFR 101.30(e)(1)

5 elements checked: 1 flagged, 4 with no issue foundIn the sample report

What the artwork can and cannot show.

Read from the label artwork

Whether the percent-juice statement is present and where it sits.
Which Nutrition Facts format the label uses.
Units and placement of the net contents statement.
The name of the drink and its qualifying terms.

Needs more than the artwork

The actual juice percentage and nutrient values.
Whether the product is a beverage or a liquid dietary supplement.
Alcoholic beverage labeling.
Type sizes that depend on real container dimensions.

Questions

Is my product a beverage or a supplement?

It depends on how the product is represented and used, not only on which Facts panel the label carries. Settle the classification first; a beverage is reviewed under the food-labeling rules and a liquid dietary supplement under the supplement rules.

Does this review cover alcohol labeling?

No. Alcoholic beverages follow a separate labeling regime. ArcheSync reviews FDA-regulated non-alcoholic beverages.

What information is needed beyond the label?

Your formulation and juice content data, the container size, and how the product is marketed. The artwork shows what the label says; those records show whether it is accurate.

Review your label before your next artwork revision.

Upload a PDF or image. Findings come back with the citation attached.

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