
Publication
BC legislature update – themes of truth, reconciliation, and transparency
The BC NDP government has introduced two changes to employment law in this session of the legislature.
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Global | Publication | April 2018
The US Food and Drug Administration does not have much of a sense of humor when it comes to the mandatory ingredient list on packaged food products. Last month, the FDA issued a Warning Letter to the Nashoba Brook Bakery in Concord, Massachusetts, for, among other violations, listing “love” as an ingredient in its granola and whole wheat bread, in violation of 21 C.F.R. § 101.4(a)(1), which requires the label or labelling of a food to display a list of ingredients, “listed by common or usual name in descending order of predominance by weight on either the principal display panel or the information panel.” According to the FDA:
“‘Love’ is not a common or usual name of an ingredient, and is considered to be intervening material because it is not part of the common or usual name of the ingredient.”
Accordingly, it concluded that the products were misbranded under 21 U.S.C. § 343(i)(2), which sets forth the ingredient listing requirement.
It does not appear, however, that the FDA targeted this bakery solely for its creative labelling: an FDA inspection earlier this year found numerous serious violations of the Current Good Manufacturing Practice regulations, including failure to clean and sanitize equipment, staff wearing jewelry while working in direct contact with food, and “[o]ne approximately one inch long crawling insect underneath exposed ready-to-eat foods in the pastry area,” as well as other labelling violations. After being issued a listing of the FDA’s inspectional observations (FDA Form 483), the bakery provided no formal response to the FDA, triggering the Warning Letter.
This case serves as a warning that food companies should avoid creative license with ingredient lists, even when the reasonable consumer would clearly not expect the “ingredient”—in this case, love—to be in the product.
Publication
The BC NDP government has introduced two changes to employment law in this session of the legislature.
Publication
The Government of Canada recently released the Regulations Amending Certain Regulations Concerning the Disclosure of Cosmetic Ingredients (the Amending Regulations) in Canada Gazette, which is now open for public comment until April 22, 2023.
Publication
On March 14, the BC government revamped its framework for proposed LNG facilities in the province. Under this new framework, proposed LNG facilities (i.e., those currently in or entering the provincial environmental assessment process) must pass an emissions test and must have a “credible plan” to reach net-zero emissions by 2030.
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