Food safety, traceability and sustainability blog



Friday Round-up (5/29/20): FDA Issues Temporary Policy to Alleviate Supply Chain Disruption

Every week FoodLogiQ will be aggregating the latest updates and resources for food businesses navigating the coronavirus disease 2019 (COVID-19) pandemic. Learn how the industry is adapting to protect and feed consumers while building resilience in the face of global crisis.

In order to alleviate supply chain disruption due to COVID-19, the FDA issued a temporary policy this week allowing food manufacturers flexibility in food labeling. The temporary easement grants manufacturers the ability to substitute an ingredient that is currently not available with a similar ingredient, without having to create a new label. This newly-created option allows supply chains to continue to flow in a seamless fashion to get products to consumers in an efficient way during this trying time.

The FDA states in the document, “Our goal is to provide regulatory flexibility, where fitting, to help minimize the impact of supply chain disruptions associated with the current COVID-19 pandemic on product availability. For example, we are providing flexibility for manufacturers to use existing labels, without making otherwise required changes, when making minor formula adjustments due to unforeseen shortages or supply chain disruptions brought about by the COVID-19 pandemic.”

Food businesses looking to take advantage of this temporary policy need to take several factors into consideration. Before making ingredient changes, there are a number of items brands need to address: 

Safety: The substitute ingredient cannot cause harm to anyone and must be free of food allergens like gluten.

Quantity: The substitute ingredient should be 2% or less by weight in the finished product.

Prominence: The substitution should not be a major ingredient, or go against a written claim about the product.

Characterizing or ingredient in name: The ingredient being replaced should not be one that is named on the package or has a material bearing on consumer purchasing.

Claims: An omission or substitution of the ingredient should not conflict with written label claims.

Nutrition/function: An omission or substitution of the labeled ingredient does not have a significant nutritional difference in the final product.

Make sure your team understands the temporary policy thoroughly prior to enacting substitutes and ensure your new ingredients are sourced from reliable suppliers by conducting virtual audits. If an intended ingredient is modified in any way, you should be in constant contact with your supply chain partners and have written documentation of that change. Having this information on hand will allow you to address any future regulatory or customer concerns that may arise.

Learn how brands like Frontier Co-op have maintained supply chain flexibility during COVID-19 disruptions by streamlining their supplier management.


Please view FoodLogiQ's COVID-19 Food Industry Resource Center for industry-specific updates, resources and information.

If your business is in need of operational guidance for navigating the COVID-19 pandemic, download our E-Book to learn how FoodLogiQ Customers are minimizing risks, or watch the corresponding on-demand webinar here.

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Posted by Julie Brown on May 29, 2020 4:00:22 PM

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