Tea Packaging Requirements from the FDA

Coming up with an excellent product is the most obvious hurdle to running a business. You can most certainly expect to have a plethora of other details to contend with, government regulations being one of them. When it comes to tea sold and marketed in the United States, it’s absolutely imperative that you strictly abide by the edicts of the Food and Drug Administration.

The agency is tasked with protecting public health by controlling and supervising food, drugs, and other related items. One way to ensure that people are safe from food and drugs that don’t pass muster is to implement packaging and labeling regulations. These are all detailed in the FDA’s Code of Federal Regulations, Title 21.

Labeling Regulation Exceptions

Bearing these requirements in mind, you need to determine whether the packaging for your tea should be labeled for resale. Take note that the packaging regulations do not apply to the following situations:

• When your tea is packaged before a customer, as in loose tea that is being sold by weight.
• When your tea is served, as in a self-service display at a dining establishment.

However, anytime you package your tea ahead of time and then have it on display on a shelf or counter for customers to pick up and buy, it has to be packaged according to the instructions of the FDA. Anything prepackaged and displayed, be it by a factory machine or a sales clerk, should comply with the agency’s labeling regulations.

Important Elements

To better understand what it is you need to do in this regard, let’s divide the discussion into the different parts of the label:

1. Principal Display Panel

This refers to the most dominant part of the label, which gets the most view or scrutiny in retail sales. It should be big enough to include all the required information. To figure out which font

size to use, determine the principal display panel measurement. This refers to the package’s surface area bearing the information. For tea boxes, cans, or pouches, just measure the height and width of the side you’ll put this on. For cylindrical containers, the area should be 40 percent of the product of the height and circumference.

What details are included in the Principal Display Panel (PDP)?

• Identity Statement

This is a statement that consists of the legal name of the food (e.g., Twinings Herbal Tea) or the tea’s common or usual name, such as “Peppermint Tea” or “Green Tea.”

In the absence of either, a descriptive term like “FRUIT TEA” would do. In cases where the nature of the food is apparent, a fanciful name for the tea that the public commonly uses would also be allowed. That’s why “DRAGONWELL” and ‘DARJEELING” would also work.

Since tea is marketed in different forms (loose leaf, tea bag, powder, etc.), the product’s particular form must be included in the Identity Statement. It should be printed in a type size close to that of text pertinent to other parts of the Identity statement, unless the optional form can be seen through the container or is represented by an appropriate image that clearly shows what form the tea is in.

Make sure that the Identity Statement is one of the most prominent texts on the panel and that it is not placed at an awkward angle. It should be in bold type in a size reasonably close to the most dominant type on the label. It should also be placed in lines parallel to the package base when it rests on display.

• Contents Declaration

The FDA requires the principal display panel to show a declaration of the content’s net quantity, expressed in weight, measure, numerical count, or a combination of these. It’s imperative that the term “net weight” be used when indicating the net quantity in weight, even if it’s in its abbreviated form, “Net Wt.” According to the American Technology Preeminence Act of 1991, the net quantity of contents must be declared in metric form, indicating weight or volume.

The Contents Declaration must be presented as a separate item on the panel, set apart by space at least equal to its text height from other information printed below or above it and space equal to double the width of the letter “N” in the type style it uses from information printed on its left or right. It should also be placed in the bottom 30 percent of the panel and aligned parallel to the package’s base in its resting position. Of course, for principal display panels that are five square inches or smaller, the content declaration no longer needs to be placed in the bottom 30 percent.

The type size should be compliant with specifications based on the area of the principal display panel. For instance, no less than a sixteenth of an inch in height on Principal Display Panels measuring five square inches or smaller. For those with a bigger area not going over 25 square inches, it should not be smaller than an eighth of an inch. For specific measurements, refer to the following:

• 1/16 in. type height for a total PDP area of 5 sq. in. or less.
• 1/8 in. for areas larger than 5 sq. in. but no bigger than 25 sq. in.
• 3/16 in. for areas larger than 25 sq. in but no bigger than 100 sq. in.
• 1/4 in. for areas larger than 100 sq. in but no bigger than 400 sq. in.
• 1/2 in. for areas over 400 sq. in.

The assumption is that it would be up to the packager to make decisions on what to put in the Contents Declaration. Still, it should be noted that a combination of numeric quantity and net weight is allowed for clarity’s sake. In cases where quantity would be the practical measure of the contents, as in the case of tea bags, it’s prudent not to assume that putting only the net weight would be enough. The logical recommendation based on what existing labels show is to indicate both the numerical count (10 TEA BAGS) and the net weight (0.9 OZ/25g).

2. Information Panel

This is the part of the label right next to the principal display panel. It usually contains information on the nutrients included, the ingredients, the name and address of the manufacturer, packer, or distributor, as well as the country of origin for imported products. If these bits of information are already reflected on the front panel, they need not also appear on the information panel. Considering that the print on the label would have to be pretty small, there are precise requirements regarding the font type and size to be used. It’s important to check out and comply with the instructions, as it can be a meticulous process.

• Nutrition Facts

Food labels must carry nutrition information unless exempt, which is the case with food that contains negligible amounts of nutrients, such as vitamins and minerals, and food components like calories, carbohydrates, fats, proteins, etc., as long as it doesn’t bear nutrition claims on the label, in other forms of labeling such as brochures, or in

advertising. This exemption applies to teas and herbal teas, but many tea brands still include Nutrition Facts, especially those that underline the antioxidant contents of tea.

• Ingredient Statement

This requirement may actually be placed on either the Principal Display Panel or the Information Panel. It should reflect a list of all the ingredients in their usual or common names, sequenced in descending order based on predominance by weight. An accurate Identity Statement like “Green Tea” or “Black Tea” on the Principal Display Panel may suffice for single-ingredient products. Even tea blends may do with just an Identity Statement as long as Camellia Sinensis is the only ingredient.

If an Ingredient List is included, it must appear on the same panel as the Manufacturer’s Name and Address.

Also, where it applies, an allergen declaration must be included in plain language, stating if the product contains or was manufactured in a facility that also handles any of the major food allergens.

• Name and Address of the Manufacturer, Packer, or Distributor

The label of your packaged tea product must specify in a conspicuous manner the name and place of business of its manufacturer, packer, or distributor. In addition, the address must include the street details, city, state, and zip code. The street address may be left out if the business is listed in a current phone or city directory.

In cases where the tea is not produced by the business that appears on the label, e.g., a U.S. distributor, the name should be qualified to show its relationship to the product. Following the example given, the qualifying phrase would be “Distributed By.”

Like the Ingredient List, this detail typically appears on the Information Panel but may also be placed on the Principal Display Panel.

• Country of Origin Markings

Besides the FDA, various government agencies, including the U.S. Customs and Border Protection, require that labels of food products of foreign origin bear conspicuous, legible, and indelible markings that will disclose the country of origin to the ultimate purchaser, e.g “Product of Japan” or “Made in Japan.”

Whenever the retail package of imported goods bears the name and address of their U.S. distributor, the word United States, or any U.S. state or city, the product’s country of origin should be indicated in close proximity and in a type size that is comparable.

Again, this information may appear on either panel.

Additional Packaging Elements

The following are other details that may be considered for inclusion:

• Nutrient Content Claim

This is a statement pertaining to the nutrient level of the product. “Gluten-free,” “sugar-free,” “high fiber,” and “low fat” are some examples. Claims have to be valid based on regulations. A Nutrient Content Claim can be displayed anywhere on the package in a type size no larger than twice the size of the Identity Statement’s font. It also follows that the package should bear a Nutrition Facts portion if there is a Nutrition Content Claim.

• Notable Dates

Food labels generally have an expiration, best-before, or sell-by date, as this is required in some states. Hence, it’s essential to check the relevant state’s food packaging and labeling regulations.

Placement-wise, the date must not mess with the labeling elements required by the FDA. It must also show at least the month and year immediately next to the explanatory phrase (e.g., best before 08/08/23).

• Barcode

The government does not mandate the inclusion of a barcode; however, retail stores often do. When including a barcode, take care to place it where it won’t interfere with the required elements.

Final Thoughts

These are just the most salient points of the regulations regarding the packaging and labeling of tea. Of course, the literature from the FDA is much more complicated, but the above discussion hopefully allows for better clarity regarding the basics.

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