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How to Efficiently Update Food Labels to Comply with Proposition 65 Changes

By BLUE Software

As if there isn’t enough change in the air with the FDA’s looming deadline for nutrition label updates, there are now high-stakes changes on the horizon for food labels in California.

California’s Proposition 65, previously known as the Safe Drinking Water and Toxic Enforcement Act of 1986, is one of the state’s most well-recognized regulations. The law requires California to publish a list of chemicals “known to the State to cause cancer or reproductive toxicity” and prohibits a manufacturer from knowingly exposing any individual to a listed chemical without first providing a “clear and reasonable warning” on the label.

As of August 30, Proposition 65 warning language will change and require the identification of at least one carcinogen and at least one reproductive toxicant present in the given product and refer consumers to a Lead Agency Website for additional information.  And the stakes for failing to comply with the label updates are high.  Out of 333 judgments in 2017, total penalties amounted to more than $167 million.

Changing Labels: It’s More Complex than it Seems

If you’re responsible for the labels and artwork on food products sold in California, chances are good that when you learned of this update, you cringed.  Why?  Because you know it’s not as simple as updating content on a single label and sending it to the production team.  Your product comes in many sizes.  You have multiple manufacturing sites.  There are cartons, inserts, and other components to consider.

And… there are a significant number of people involved in the labeling process – from those who provide input, to those who approve content and design, to those who are responsible for the creation of the label.  With so many stakeholders involved in the label production process, it’s difficult to ensure everyone involved has visibility into the updated labeling project and the ability to easily provide input and approve the new labeling assets.

Finally, you know your label production process from design to distribution rarely follows a linear path.  The odds are good that at the same time you’re changing the warning label for products sold in California, there will be another label-changing event that takes place.  For example, a manufacturing site will be changed or added, or yet another regulatory change will be required.  You now have changes on top of changes, and you need to make decisions about how to track all of these versions.

How to make it easier: Single source of truth.

The first step to make label and artwork changes easier is to get organized.  A good Label and Artwork Management solution will provide you with a global repository for all label assets that is easy to access at anytime from anywhere.  This repository will be your “single source of truth,” housing the latest versions and featuring easy-to-use filters, searches, and sorts for quick asset retrieval.

How to Make It Easier: Online Collaborative Proofing

A Label and Artwork Management solution also streamlines the label approval process by enabling online collaborative proofing.  Multiple stakeholders can simultaneously access a single platform to view the label asset and automatically compare the new statement to the old statement, the new version to the previous version. You eliminate version confusion, endless email threads, and hard copies of your label and artwork assets lying around the office.  Instead, your team can simultaneously proof online, and in real time, while creating an auditable trail of feedback.  Add the power to approve the new label once and then execute approved changes across multiple stock-keeping units (SKUs), and now teams are achieving quality results at scale.

How to Make It Easier: Provide Context to Approval Workflows

Finally, a Label and Artwork Management solution allows the project owner to provide clear review instructions and it enables easy access to relevant source documentation such as approved regulatory content. Often, reviewers are unsure what to check due to lack of context, but this is easily remedied by guidance documents detailing who is requesting the change, who is approving the request, and what documentation is available to support the change.

How to Get Started

BLUE Software has developed a comprehensive list of Label and Artwork Management user requirements for packaged foods companies who sell products in California, including the features highlighted above.  Download our sample requirements document to jumpstart your label update process and prepare for additional regulatory changes, which are sure to come!

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