Deli Meat Label Requirements for Private Label: A Plain-English Guide

This guide explains the general federal rules so you know what to expect. It isn't legal advice. Confirm requirements for your products with your supplier and regulators, especially for any claim you want to make.

Which rules apply: USDA or FDA?

The deli case falls under two federal agencies.

• USDA's Food Safety and Inspection Service (FSIS) is responsible for making sure the commercial supply of meat, poultry and egg products is safe, wholesome and correctly labeled. Its jurisdiction generally covers products containing more than 3 percent meat or 2 percent poultry. Deli turkey, chicken, ham, roast beef, corned beef, pastrami, salami and prosciutto fall here.
• The FDA covers foods outside FSIS jurisdiction. That usually includes deli cheeses and many salads, such as potato, macaroni and cole slaw. Salads made with meat or poultry can fall under FSIS depending on how much they contain.

The rest of this guide focuses on meat and poultry labels, because that is where most store-brand deli questions come up. If your program includes cheeses or salads and cream cheeses, ask your supplier about FDA labeling for those items.

What a meat or poultry label must show

Under the federal meat labeling rules, labels have to show the following on the principal display panel (the part of the package a shopper sees first), unless the rules allow it elsewhere:

Required item	What it means for your store brand
Product name	The standardized name if one exists for the product; otherwise its common name or an accurate description. "Oven Roasted Turkey Breast", not just a fanciful name.
Ingredients statement	Required when the product is made from two or more ingredients.
Name and place of business	When your store is shown as the distributor, the rules call for a phrase such as "Prepared for" with your name, plus city, state and ZIP code (or a street address if you aren't listed in a directory).
Net quantity	An accurate statement of the net weight or quantity of contents.
Inspection legend and establishment number	The official USDA mark of inspection and the number of the establishment that produced it.

The label approval rules also list these as mandatory features where they apply:

• A handling statement, such as "Keep Refrigerated", for products that need special handling to stay wholesome.
• Nutrition labeling, unless an exemption applies.
• Safe handling instructions, which are required on meat and poultry that hasn't been processed to make it ready to eat. Most fully cooked deli meats are ready-to-eat products, but confirm for each item.

Required information must be prominent enough that an ordinary shopper is likely to read and understand it, and it must be in English (Spanish may replace English, except for the inspection legend, for products sold only in Puerto Rico).

Generic approval vs. labels that need review

This is the part that most affects how fast a private label line gets to your case.

Generic approval

Labels that carry all the required information and no special statements or claims are "generically approved". The producing establishment can use them without first submitting them to FSIS, as long as they follow the rules and aren't false or misleading. FSIS checks samples of these labels from establishment records.

Special statements and claims need submission

Labels with special statements and claims have to be submitted to FSIS and approved before use. Under the rules, these include:

• "Natural" claims;
• health claims, including heart symbols;
• ingredient and processing-method claims;
• claims about how animals were raised, such as "no antibiotics administered";
• products labeled as organic (except where only individual ingredients are labeled organic);
• statements not defined in the federal regulations or FSIS labeling policy.

Some things are specifically not treated as special claims, including allergen statements, negative claims about ingredients that aren't in the product (for example "No MSG Added"), nutrient-content statements that follow the rules (such as "low fat"), and many geographic and country-of-origin statements.

"Product of USA" and "Made in the USA"

These claims have their own rules. For single-ingredient meat products they may be used under generic approval only when the animals were born, raised, slaughtered and processed in the United States. Multi-ingredient products have additional conditions. If origin matters to your customers, ask your supplier whether a specific item qualifies before you put it on the label.

Who does what

Task	Usually handled by
Brand name, design and look of the label	Your store and your designer
Required information and its placement	Your supplier's producing establishment, checked with you
Submitting labels with special claims to FSIS	The producing establishment
Keeping records of labels used	The producing establishment
Deciding which claims are worth making	You, with your supplier's advice

A label checklist for your store brand

1. The product name is accurate and specific.
2. Ingredients are listed if there is more than one.
3. Your store name appears with "Prepared for" (or similar) and your place of business.
4. Net weight is shown.
5. Space is left for the inspection legend and establishment number.
6. The handling statement is included ("Keep Refrigerated" for most deli items).
7. Nutrition labeling is included unless an exemption applies.
8. Safe handling instructions are included if the product is not ready to eat.
9. Any special claim ("natural", organic, raising claims) has been flagged early for approval.
10. Your supplier has reviewed the final artwork before printing.

Tips that save time

• Launch plain, add claims later. A clean, accurate first label gets your line into the case sooner. You can add approved claims in a later print run.
• Use real product descriptions. "Black Forest Ham" and "No Pump Oven Roasted Beef" say what the product is, and customers like that.
• Keep one template. A consistent label layout across your line makes reviews faster and your case look like a brand.

Common label mistakes to avoid

• A name that doesn't describe the product. A catchy brand name is fine, but the product name itself has to say what the food is.
• Claims added at the last minute. Words like "natural" or claims about how animals were raised trigger a submission. Adding them after artwork is approved can hold up your launch.
• Required information squeezed out by design. Required statements have to be prominent and readable. Leave room for them from the first sketch.
• Origin claims assumed, not checked. "Product of USA" has specific conditions. Ask before you print it.
• One label reused across different products. A smoked turkey and a peppered turkey have different names and may have different ingredients. Each needs its own accurate label.
• Forgetting the cheese and salad rules. If your line includes FDA-regulated items, their labels follow different rules from your meats.

How Longview helps

Longview Trading builds custom private label deli programs, with products produced in HACCP-certified processing facilities. We will work with you on product names, specs and label details for each item in your line, from turkey and chicken to hams and roast beef. Read our step-by-step guide on launching a private label deli line, or ask for a quote to start the conversation.