Food and Beverage Manufacturers Contacted Re: Corn Labeling Requirements

The FDA's Food and Cosmetic Information Center (FCIC) and Technical Assistance Network (TAN) have confirmed that corn/corn-derived ingredients are not exempt from food labeling requirements (see references below).  As a result, I have contacted the following world-wide food and beverage manufacturers concerning corn labeling requirements.

AdvancePierre Foods, @AdvancePierre

Agropur Cooperative, @agropurcoop

Ajinomoto Park, @AJINOMOTOPARK

Anheuser-Busch, @AnheuserBusch

Annie's Homegrown, @annieshomegrown

Archer Daniels Midland Company, @ADMupdates

Arla Foods USA, @ArlaFoodsUS

B&G Foods, Inc., online contact form

Bacardi, @BACARDI

Barilla US, @BarillaUS

Barry Callebaut, @BCgroupnews

Bertolli, @Bertolli

Betty Crocker (General Mills), @BettyCrocker
Bigelow Tea, @bigelowtea

Blue Bunny (Wells Enterprises, Inc.), @Blue_Bunny

Breyers, @Breyers

BRF Brasil Foods, @BRF_Brasil, @BRF_Global

Brown-Forman, @BrownFormanJobs

Bunge Limited, Email: susan.burns@bunge.com

Campbell Soup Company, @CampbellSoupCo

Cargill, @Cargill

Chicago Bar Company (see RXBAR)

Chiquita, @Chiquita

Chobani, @Chobani

CHS Inc., @CHSGovAffairs

Coca-Cola Amatil, @CocaColaAmatil

Coca-Cola Company, The, @CocaColaCo

Conagra Brands, @ConagraBrands

Constellation Brands, @cbrands

Dairy Farmers of America (DFA), @dfamilk

Danish Crown, Email: dc@danishcrown.dk

Dannon Company, The, @Dannon

Danone Food Company, @Danone

Dean Foods Company, @deanfoods

Del Monte Foods, @DelMonte

Diageo, @Diageo_News

Dole Food Company, @DoleTweets

Doritos, @Doritos

Dr Pepper Snapple Group, @DrPepperSnapple

Dunkin' Donuts, @dunkindonuts

E. & J. Gallo Winery, @gallocareers

FEMSA, @FEMSA

Ferrero UK & Ireland, @FerreroUK

Flowers Foods, @flowersfoods

Fonterra, @Fonterra

Foster Farms, @FosterFarms

FrieslandCampina, @FrieslndCampina

General Mills, @GeneralMills

Glanbia, @GlanbiaPlc

Gorton's Seafood, @gortonsseafood

Grassland Dairy, @GrasslandDairy

Grupo Bimbo, @Grupo_Bimbo

Heineken, @Heineken_AR

Hershey Company, The, @HersheyCompany

Hidden Valley, @HVRanch

Hormel Foods Corporation, @HormelFoods

Hostess Brands, LLC, @Hostess_Snacks

HP Hood, @hphood

Ingredion, Inc., online contact form

Ito En, @ITO_EN

J R Simplot, online contact form

J&J Snack Foods, @JJSnackFoods

JBS, online contact form

JM Smucker Company, The, @smuckers

Johnsonville, @Johnsonville

Juicy Juice, @JuicyJuiceUSA

Kellogg Company, @KelloggCompany

Kerry Group, online contact form

Keystone Foods, online contact form

Kraft Heinz Company, @KraftHeinzCo

Krispy Kreme Doughnut Corp., @krispykreme

Lactalis American Group, Inc., online contact form

Land O' Lakes, Inc., @LandOLakesKtchn

Libby's Brand Holding, online contact form

Lindt Chocolate USA, @Lindt_Chocolate

Little Debbie, @LittleDebbie

Maple Leaf Foods, @MapleLeafFoods

Marfrig Global Foods, online contact form

Mars, Incorporated, @MarsGlobal

McCain Foods Limited, @McCainUK, @McCainFoodsGB

McCormick Corporation, @McCormickCorp + online contact form

McCormick Spices, @mccormickspices

McKee Foods (see Little Debbie)

Meiji America, @meijiamerica

Mizkan America, Email:  Customer.Service@Mizkan.com

Molson Coors Brewing Company, @MolsonCoors

Mondelez International, @MDLZ

Morinaga Milk Industry, online contact form

Morton Salt, @mortonsalt

Mott's, @Motts

Nestlé US, @NestleUSA

Nissin Foods Group, @OrigCupNoodles

Ocean Spray, Inc., @OceanSprayInc

Oetker Group, Dr. Oetker Baking UK, @DrOetkerBakes

Olam International, @Olam

OSI Group, online contact form

Parmalat Spa, Email: parmalat@consumer-care.it

Pepperidge Farm, @PepperidgeFarm

PepsiCo, @PepsiCo

Perdue Farms, @PerdueFarms

Pernod Ricard, online contact form

Pillsbury, @Pillsbury

Pinnacle Foods, Inc., @pinnaclefoods

Post Consumer Brands, online contact form

Quaker Oats, @Quaker

Ragu (Mizkan America), @ragusauce

Red Bull, @redbull

Reser's Fine Foods, @Resers

Rich Products Corporation, @RichProducts

RXBAR, @RXBAR

Saputo, online contact form

Schreiber Foods, online contact form

Schwan's Company, @SchwansCompany

Smithfield, @SmithfieldBrand

Smithfield Foods/WH Foods, @SmithfieldFoods

Sodiaal, online contact form

Stonyfield Organic, @Stonyfield

Stouffer's, @stouffers

Sudzucker, Email: info@suedzucker.de

Sunkist Growers, @Sunkist

Suntory, @SuntoryGlobal

Tate & Lyle, online contact form

The Honest Company, @Honest

TreeHouse Foods, online contact form

Tropicana, @Tropicana

Tyson Foods, @TysonFoods

UnileverUSA, @unileverusa

Van's Foods, @vansfoods

Vion Food Group, online contact form

Welch's, @Welchs

Wells Enterprises, Inc., online contact form

WhiteWave Foods (see Danone Food Company)

Yoplait Yogurt, @Yoplait

Corn/Corn-Derived Ingredients are Required on Food Labels, FDA's FCIC/TAN (Revised 6/20/18)

https://cornallergyadvocacyresources.blogspot.com/2018/06/corncorn-derived-ingredients-are.html

Critical Corn Allergy References, Studies, Statistics, & Petitions

(Includes my submission to The Joint Commission, Congress, FDA, & U.S. Dept. of Health requesting emergency mandate that hospitals stock corn-free foods, liquids, & drugs.)

https://cornallergyadvocacyresources.blogspot.com/2018/04/corn-allergy-reference-links.html

My February 25, 2018, certified letter to the U.S. Department of Health & Human Services Re: mandate that hospitals stock corn-free foods, fluids, & drugs for the safety of corn-allergic patients.

https://cornallergyadvocacyresources.blogspot.com/2018/02/my-february-25-2018-letter-to-us.html

My March 27, 2018, Certified Letter to the ACAAI  Re: Cornstarch and Corn Syrup

https://cornallergyadvocacyresources.blogspot.com/2018/03/my-march-27-2018-certified-letter-to.html

Diane H., Corn Allergy Advocate

Corn Allergy Advocacy/Resources
https://cornallergyadvocacyresources.blogspot.com/
@CornAllergy911

Sources:

https://www.foodengineeringmag.com/2017-top-100-food-and-beverage-companies

https://en.wikipedia.org/wiki/Category:Food_manufacturers_of_the_United_States

Corn/Corn-Derived Ingredients are Required on Food Labels, FDA's FCIC/TAN

CRITICAL UPDATE, JUNE 16, 2020

FDA CONFIRMS THAT CORN IS EXEMPT FROM FDA LABELING REQUIREMENTS

https://cornallergyadvocacyresources.blogspot.com/2020/06/fda-confirms-that-corn-is-exempt-from.html

(Revised June 20, 2018)

My First Inquiry to the FDA’s FCIC/TAN:

Corn-allergic patients are currently required to provide our own previously-prepared corn-free foods, liquids, and medications while hospitalized (the only corn-free product stocked by hospitals is straight, saline-only IV fluid). What would happen if our admissions were due to an emergency? Please let me know how to proceed with a request that hospitals be mandated to stock corn-free foods, fluids, and medications (compounded to exclude corn) for the safety of corn-allergic patients. After my surgery in March, 2017, the hospital could not comply with the surgeon-ordered, liquid-only diet; since all of the liquids they offered me contained corn even though my allergy to corn was clearly indicated in my medical records. The hospital failed in their responsibility to contact the manufacturers of each liquid to confirm if the products contained corn/corn derivatives.  Therefore, a corn allergy is potentially a life-threatening diagnosis; since hospitals are ill-equipped to treat/nourish us. Thank you!

The Food and Drug Administration’s (FDA) Food and Cosmetic Information Center (FCIC)/Technical Assistance Network (TAN) has prepared a response for case number 00167188.

First Reply by the FDA’s FCIC/TAN, May 25, 2018:

Good afternoon, we are sorry to hear about your experience. We would like to offer a point of clarification: while corn is not one of the eight major allergens, it still must be listed as an ingredient in foods that contain corn. Corn is not exempt from FDA labeling requirements. [Emphasis added.]

Hospitals and other public health or medical facilities are not regulated by FDA. You may want to contact your state and local health officials to offer your suggestion regarding food service facilities in hospitals.

We hope this information is helpful.

Thank you for contacting FDA’s FCIC/TAN.

My Second Inquiry to the FDA’s FCIC/TAN:

Case 00167188: Food/Allergen [ ref:_00D60KbN0._500t0AfLBa:ref ]

The FDA representative responding to my inquiry does not understand that corn/corn derivatives, as of now, are EXEMPT from FDA labeling requirements. I have had a corn allergy for 10 years; and, as a result, I must contact manufacturers prior to consuming their products due to the fact that corn/corn derivatives do not have to be labeled; e.g., I experienced severe reactions to Mott's and Ocean Spray 100%-advertised "pure" fruit juices. When I contacted these companies, they explained that corn/corn-derived ingredients in their products (corn-derived ascorbic acid) were exempt from labeling requirements, since corn has not been declared an official allergen. The corn-derived ascorbic acid was "hidden" under "natural flavors." Another severe reaction was to Morton's iodized salt. Again, the company explained that their iodized salt contains corn-derived dextrose which is EXEMPT from FDA labeling requirements.

The Food and Drug Administration’s (FDA) Food and Cosmetic Information Center (FCIC)/Technical Assistance Network (TAN) has prepared a response for case number 00167300.

Second Reply by the FDA’s FCIC/TAN, May 30, 2018:

Greetings. We are sorry to hear that you were unsatisfied with the response to case #00167188, but the answer provided to you was correct: products containing corn are not exempt from the FDA labeling requirements found in 21 CFR part 101. [Emphasis added.] However, as previously stated, corn is not one of the eight major allergens as defined by Federal law, namely the Food Allergen Labeling and Consumer Protection Act. If you feel that the legal definition of food allergens should be expanded to include corn, we encourage you to contact your elected officials.

Thank you for contacting FDA’s FCIC/TAN.

My Third Inquiry to the FDA’s FCIC/TAN:

Case 00167300: Complaint [ ref:_00D60KbN0._500t0AfRnX:ref ]

I called Mott's, Ocean Spray, and Morton's Salt companies on June 1, 2018. These companies (to which I experienced severe allergic reactions to the undeclared corn-derived ingredients in their products; e.g., corn-derived dextrose, corn-derived ascorbic acid) have explained to me over the last 10 years that due to the fact that corn has not been declared an official allergen, corn/corn derivatives are exempt from FDA labeling requirements. I explained to them that the FDA has stated to me, in writing, that corn/corn-derived ingredients must be labeled, and shared with them the FDA regulation you shared with me. I received a call from Morton's Salt on June 5, 2018; and, once again, they declared that they are not required to label corn in their products since corn has not been declared an official allergen (I cannot consume iodized salt due to corn-derived dextrose).

Every company I have contacted since I acquired an allergy to corn in 2008 (confirmed in 2011) have reiterated the same declaration. Only after corn is declared an official allergen will companies be required to label corn/corn-derived ingredients.

I have contacted all 535 members of Congress six times in the last 4 1/2 years. They, too, have confirmed that companies are exempt from labeling corn, because corn has not been declared an official allergen. 

My February 25, 2018, certified letter to the U.S. Department of Health & Human Services Re: mandate that hospitals stock corn-free foods, fluids, & medications for the safety of corn-allergic patients.
https://cornallergyadvocacyresources.blogspot.com/2018/02 

Third Reply by the FDA’s FCIC/TAN, June 20, 2018:

The Food and Drug Administration’s (FDA) Food and Cosmetic Information Center (FCIC)/Technical Assistance Network (TAN) has prepared a response for case number 00168167. 

While we appreciate your interest in this subject, we cannot be of further assistance as the Federal laws and regulations are clear on the food labeling and allergen labeling requirements.  In hopes of clearing up your confusion, we will reiterate our previous explanations. We also encourage you to review our previous correspondence and the Federal regulations we have cited for further information.

Corn is not exempt from FDA labeling requirements. Per the Food, Drug, and Cosmetic Act (FD&C Act):

[A food shall be deemed to be misbranded] Unless its label bears (1) the common or usual name of the food, if any there be, and (2) in case it is fabricated from two or more ingredients, the common or usual name of each such ingredient; except that spices, flavorings, and colors not required to be certified under section 721(c) 29 unless sold as spices, flavorings, or such colors, may be designated as spices, flavorings, and colorings without naming each. (Sec. 403(i))

This is further clarified in 21 CFR 101.4, which elaborates upon the requirements for ingredients to be listed on food labeling.

The FD&C Act also states that "The introduction or delivery for introduction into interstate commerce of any food, drug, device, tobacco product, or cosmetic that is adulterated or misbranded [is prohibited]" (Sec. 201(a)).

We hope this clarifies that foods containing corn must include that information in their ingredient lists.

Corn derivatives are not exempt from FDA labeling requirements.Contrary to your previous assertion, regardless of whether they are derived from corn or not, dextrose and ascorbic acid are not exempt from FDA's food labeling regulations as codified in 21 CFR part 101. They are NOT, however, subject to food allergen labeling requirements because corn is not one of the eight major allergens as defined by the Food Allergen Labeling and Consumer Protection Act. 

Dextrose and ascorbic acid must be identified as ingredients in foods that contain them as "dextrose" and "ascorbic acid."

Furthermore, ascorbic acid is typically used as a preservative or nutrient, not as a flavor. If it is included in a food or beverage as a preservative or nutrient, it cannot be "hidden" under natural flavors--it must be identified by name.

We hope this is helpful. 

Thank you for contacting FDA’s FCIC/TAN.

View popular Food Safety Modernization Act (FSMA) questions and answers identified by the Technical Assistance Network (TAN), on ourwebsite.

Diane H., Corn Allergy Advocate

Corn Allergy Advocacy/Resources
https://cornallergyadvocacyresources.blogspot.com/
@CornAllergy911