A cheaper (and totally legal) way to do nutrition labels
When Christopher Wilson needed Nutrition Facts labels for LunaGrown, his line of handmade jams, all his options were pricey and unappealing. Lab testing would cost several hundred dollars per product. Consultants and online services weren’t much cheaper. And software solutions cost thousands of dollars.
“I did a lot of research,” Wilson says. “And my first reaction was—oh my god, you’re kidding me. That’s what it’s going to cost to make a friggin’ label? I was blown away.”
Lev Berlin had a similar experience. In 2011, he worked for SlantShack, a small-batch custom jerky company. (Today, the product is sold nationally via Whole Foods.) SlantShack’s online “Build-a-Jerky” feature allows customers to mix and match ingredients—fun for customers, but a labeling nightmare. As SlantShack started to scale up and needed dozens of nutrition labels, Berlin couldn’t believe how much they’d cost.
“There was no Web 2.0, easy-to-use, user-friendly option for a food entrepreneur doing it for the first time,” Berlin says. “It’s a big barrier to entry.”
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We caught up with #LFLer Lev Berlin of ReciPal at the #fancyfoodshow Do you need to create a nutrition label for your food product? Then click the 'Package design' tag on localfoodlab.com and check out ReciPal or read his blog post at blog.localfoodlab.com #foodstartups #wffs14
So Berlin spent the past four years building ReciPal, a cloud-based service that eliminates the need to send samples to a lab, or download software, or hire a consultant. Simply enter your product’s recipe, and—with a few minutes’ work—you’ll have a JPEG or PDF of your retail-ready nutrition label. Each finished file costs only 19 bucks.
Database Analysis: The (Free) Alternative to Lab Testing
There’s a persistent misconception among food entrepreneurs that lab testing is the only way to get an FDA-compliant label. It’s not the case. FDA understands it wouldn’t be feasible to lab-test all prepared foods and allows companies to use standard, generic estimates instead. In the United States, these are typically based on a number of large databases of ingredients. Some of these are proprietary and cost money to use, but the two most widely used are free, public resources maintained by USDA: the National Nutrient Database for Standard Reference, which contains nutritional data for more than 8,000 ingredients, and the USDA’s tables for yield and retention factors, which lay out how varying cooking and processing methods affect nutritional content.
Database analyses: good enough for government?
The good news is that, if you can find valid nutritional estimates for all your ingredients, ReciPal—and database estimates generally—are good enough. FDA knows that approximation is inevitable in the labeling process. Nutritional content is in perpetual flux: it will change somewhat from batch to batch, season to season, year to year. That’s why generic estimates make so much sense for the industry—they’re based on averages that account for naturally occurring fluctuations. In this regard, database analyses have lab testing beat: If the sample you send a lab happens to be an outlier, the more precise data may paradoxically be less accurate than a database estimate.
As a result, FDA doesn’t insist on 100 percent accuracy. As long as your label comes within 20 percent of actual nutritional values, you’re in the clear. Audits are rare, and if you’ve used correct math and figures from a valid, FDA-accepted database, the agency will work with you to resolve any discrepancies.
Just be sure not to make any health claims—“low-fat,” “sugar-free,” and so on—unless you’re sure your product meets the legal definition of those terms. Steve Zoller explains that FDA more actively regulates health claims, and will recall products if claims that can’t be backed up with facts.
If you’re comfortable with math, and know your way around an Excel spreadsheet, you can use these to do your own FDA-compliant calculations, free of charge. That’s what many labeling consultants do. “If any entrepreneur has all the nutrition data for all of the ingredients they’re buying, they could essentially figure it out by themselves if they want to set up a lot of time doing math or set up a spreadsheet,” says Steve Zoller, a consultant who specializes in food nutritional labeling and compliance.
That’s how Berlin solved SlantShack’s labeling needs, but along the way he started feeling that other entrepreneurs might be willing to pay him a few bucks to spare them the hassle. He started developing ReciPal.
How ReciPal Works
At heart, ReciPal is a fancy Excel sheet that plugs directly into USDA data and helps you calculate nutritional values. (It has some extra features, but we’ll get to those in a minute.) You select ingredients from a list and enter quantities, using a handy dropdown that self-populates with appropriate units of measure—salted butter, for instance, can be added by cups, grams, or sticks. (Some units—for example, a “sprig” of dill?—can be subjective and require some thought.) A few additional features allow for more complicated calculations. A “loss function,” for instance, factors in changes that occur during production, such as liquid boiled away or batter left in the mixer.
Once the ingredients and proportions are set, the program asks you to set your batch and serving sizes. Then—presto—you get to view and download your label (video here). The first three labels are free. From there, it’s $19 a label, or $49 a month for an all-you-can-eat, cancel-anytime subscription. The software flags obvious errors, but if you’d like an extra layer of security, Berlin will double-check your label for an extra $20. For larger operations—and a higher monthly fee—Recipal can factor in price costing and inventory management, essentially operating as a no-frills ERP system.
Do you really need a label?
Not all food products require a nutrition label. Here are the basics, according to the FDA’s Small Business Nutrition Labeling Exemption Guidance:
You’re exempt if your annual gross food sales are less than $50,000
If you have fewer than 10 full-time employees, you’re exempt for any product that sells less than 10,000 units a year
If you have fewer than 100 full-time employees, you can apply for exemption for any product that sells less than 100,000 units a year
Even if you’re entitled to an exemption, it may still be a good idea to have a nutrition label. It looks professional, and if you’re offering a healthier or less-processed product, it can help differentiate your product.
“It’s very important to have nutrition labels these days,” says Christopher Wilson, owner of LunaGrown, a jam producer. “When you’re a small company based on keeping it as clean as it can be, you want the public to know. Look, I’m proud of this. This is what I’ve done.”
Wilson, a ReciPal user, says his nutritional label has helped him sell more product by helping him demonstrate differences between his product and its big-food competitors—Smuckers, for instance, has more than twice the sugar of LunaGrown jam. Without the label, customers weren’t always convinced. With them, they can see the disparity for themselves.
The label “really has made a big difference,” Wilson told me. “For me, it’s been a wonderful help.”
For many products, ReciPal is a viable, low-cost alternative. “It’s a better bang for the buck,” says Christopher Wilson. “We don’t mind spending the money when the money has to be spent, but it’s tough to find good, affordable tools like what [Berlin] has created.”
For others, though, ReciPal may not be quite enough. The USDA database ReciPal relies on is extensive, but it can fall short on new, exotic, or specialty ingredients. Genuine Grub’s Dan Fruin, for instance, told me he wasn’t able to find the specific type of napa cabbage he uses in his kimchi. You can add your own custom ingredients—but finding the nutritional data is up to you.
And certain preparation methods may be too complex for the database approach. Berlin says that fried foods—which can vary widely in nutritional content once prepared—are best left to labs. Fermented foods also pose problems. Fruin knows how much salt he adds in the brining process for his kimchi, but not necessarily how much remains when he discards the excess water or what fermentation does to the raw product’s nutritional profile.
“It looks like a great resource,” Fruin wrote me in an e-mail. “However, more detailed processes like mine still require a ‘real’ food lab.”
ReciPal won’t be right for every business, especially those who use unusual ingredients or complex preparation processes. For others, though, it should make the nutrition labeling simpler and more affordable for small- to mid-size businesses—and that’s a good thing.