Ask Allan


Is it true that the USDA has legally defined a sandwich?

Yes. In fact, Office of Policy of the Food Safety & Inspection Service of the USDA has issued a tome called the “Food Standards Labeling Policy which provides separate definitions of “sandwich—open” and “sandwich-closed” along with hundreds of other helpful definitions such as chili, pizza (currently subject to review) and salami.

The sandwich definition is particularly important because closed sandwiches can be made in a facility that is not USDA inspected, but open sandwiches have to be made in a USDA inspected facility. So is a rolled sandwich open or closed?

Note: USDA jurisdiction is limited to products containing meat or poultry. Products subject to USDA jurisdiction must be made in a USDA licensed facility and unlike products under the jurisdiction of the FDA, labels on meat and poultry products, must receive prior USDA approval.

Finally, we heard a rumor that USDA is revising the definition of pork to “2002 Farm Bill.”



When we discuss labeling of foods and supplements you often refer to the "NLEA." What does it stand for?

NLEA refers to the Nutrition Labeling and Education Act of 1990, which is the law that directed the FDA to enact its current regulations on the labeling of nutrient content of food and dietary supplements (i.e., the “Nutrition Facts” box part of the label). NLEA is our short hand reference to this required information as well as other information that is required to be on the label such as ingredient statement, net contents, and food name.



What are the “PDP” and the “IP” and how do they differ?

PDP stands for the Principal Display Panel and IP stands for Information Panel. Both are legally required items on a label. The PDP is the front and/or top portion of a product’s label that identifies the product by either its standard of identity or, if it has no standard of identity, its common or usual name, and states its net weight. Various disclosures may also need to appear on the PDP such as the use of artificial flavorings or colors. The IP, which normally appears on the right side of a label, contains the NLEA information discussed above and an ingredient statement. In addition to the information required to be published on either the PDP or IP, other information such as the manufacturer’s signature is required to appear on the label. By the way, marketing type copy on a label is referred to as “romance copy.”