In a warning letter sent to Food for Life dated 27 May, the regulator said that it had identified three violations in regards to labelling on the group's Spelt Bread following an inspection at its production facility between November and December 2007. The violations, which relate to section 403 of the Federal Food, Drug, and Cosmetic Act, include the misbranding of a wheat-derived ingredient - spelt - as 'an alternative to wheat' and a failure to mention the presence of trans fats in the product. The letter highlights the importance to manufacturers of ensuring that any potential allergen is correctly labelled on a product to avoid potential repackaging and rebranding of goods. Allergens Under the regulations, the FDA defines egg, fish, Crustacean shellfish, tree nuts, wheat, peanuts, and soybeans, and any products from which they are derived as allergens. Any food, which is not therefore a raw agricultural commodity and contains an ingredient containing one of the major food allergens, must use one of two designations:
The word 'contains' followed by the particular allergen present
Brackets alongside a specific ingredient stating what allergen it is derived from
Violations According to the FDA, the three violations of these rules highlighted during the inspection included an alleged failure by the group to mention that its Food For Life Spelt Bread contained the allergen wheat on its label. In addition, the regulator raised concern over the outer carton of the Spent Bread product, which it said contained a sticker saying the product was "Wheat-Alternative Spelt Bread". Similarly, the FDA said that label bearing the statement of identity for the bread suggested the product offered "an alternative to wheat," which it claimed could suggest that the product was entirely wheat free. "However, this product contains spelt, which is a species of wheat," stated the regulator. The final violation highlighted by FDA during its inspection was the company's failure to declare the presence of tran fat in its Food For Life Wheat Alternative Fruit Juice Sweetened Spelt Bread. A spokesperson for Food for Life was unavailable for comment at the time of publishing.