Getting product labels approved for your San Diego Cottage Food Operation is one of the bigger challenges owners face to getting their applications approved or renewed. Modified label requirements can impact both the design of your labels, and whether or not they get approved. Learn what is new for labels before you waste a trip to the health department.
San Diego county requires specific wording on the label to reflect proper approval, and it varies slightly depending on whether you have (or want) an A permit or B permit. For an A permit, it should say,
However, if it is for a B permit, the word permit is substituted for registration so that it would read
When submitting a new application as a first time CFO, leave 6 spaces (marked with x’s) to be filled in with the actual number when approved.
If you are not creating the product, but simply repackaging it from a larger bulk purchase, the label should read, “Repackaged in a Home Kitchen.”
Primary and Secondary Labels
Primary labels must still be on the top or front of the packaging. As of 2014, ingredient and allergen information can be on a separate, secondary label affixed to a different location. This gives many CFOs more flexibility in their label design–especially if they have a long list of ingredients. The secondary label can be placed on the side, bottom, or a separate area on the front of the packaging.
Listing Your Address
Some people are uncomfortable printing the details of their home address on their labels. Federal and CA laws require a food manufacturer to put their name and complete address on the label which means, to a CFO, your home address. But, there is a ‘work-around.’ The law also says that if your business name and full address are posted in a telephone directory (online or physical book), you may list just your city, state and zipcode on the label. (If you choose this, Cottage Foods Sandie suggests you provide proof of your phone directory listing when you submit your labels and application. This is a new development and not everyone may be aware of the change.)
Be sure, though, that you have your contact information on your labels (website, email, and/or phone number) so that customers can reach you. Don’t miss sales because people can’t place orders!
California Cottage Food Operators are still exempt from having to include a nutrition label specifying the nutrition content of their product. However, if you want to use any of the words “free, low, reduced, fewer, high, less, more, lean, extra lean, good source, and light” you would need a nutrition label. The good news is that the county will allow nutrition analysis either from a laboratory OR an online source. There are a number of free online nutritional analysis sites. Watch for a post on this subject coming soon.
Only the words, “Made in a Home Kitchn” (or “Repackaged in a Home Kitchen”) must be in 12 point type. Otherwise, the smallest font used must still be 1/16 of an inch tall as measured by the lowercase “o”.
Submitting for Approval
San Diego Environmental Health Department prefers you submit samples of your labels on regular paper rather than the actual label. This allows them to make edits and suggest changes more easily. Labels should be submitted in person with the entire application for a new or renewed permit. Remember, you need a separate label for every product and every flavor or variation.
When starting, try to focus on the products and flavors that you have found to be most popular. Having too many labels can cost an additional $142 to review. However, having too few products means you might need to add more during the year. Mid-year review of new labels will cost another $142. Be wise in choosing your menu! Five or fewer labels can generally be reviewed while you wait. More than five may take up to 5 days. Depending on the complexity, 10-12 labels can usually be reviewed within the one hour time frame covered by the application fee.
So while most of the basic requirements remain the same (must list common product name, the words “Made in a Home Kitchen” must be in 12 point font, etc.) some wording changes are important to know before wasting a trip to the health department. Other changes may provide greater flexibility for your label design and packaging.
The greatest delay in approvals results from label modifications. Make sure your food is on the California Cottage Food Operations approved food list, that your ingredients are listed in order of greatest to least quantity by weight, and that your wording, font type, etc. are in order. For further information, see the example provided by the San Diego Environmental Health Department HERE.