USDA Revises Food Kit Product Labeling Guideline

 USDA issued a revision of its food Kit Product Labeling Guideline.  Food kits (an assembly of ingredients sold together as a unit with the idea that the customer will prepare the specific food themselves) are becoming more popular. 

In the guidance, the agency announces

• FSIS no longer will provide  mandatory inspection services for the assembly of kits as described in this guideline and that such kits are eligible for FSIS voluntary inspection.  Historically, the Agency has required kit products purporting to be meat or poultry products to be assembled under FSIS inspection. After further evaluation, the Agency has determined that the act of assembling a kit product whose label makes reference to meat or poultry in its name does not need to be done under FSIS inspection, as long as certain conditions are met:

1. The meat/poultry component is prepared and separately packaged under FSIS inspection and labeled with all required features, including:

Product name

,Handling statement (e.g., Keep Refrigerated), if product is perishable,

USDA legend and establishment number of the official establishment that packaged and labeled the meat/poultry component, 

Name and address of the manufacturer, packer, or distributor,

Ingredients statement (if composed of more than one ingredient), and

Safe handling instructions if the meat or poultry component is not ready-to-eat

2. The outer label for the kit product identifies all the individual components in the kit; and

3 .The outer kit label clearly identifies the product as a single unit or “kit,” such as “Chicken Barbecue Dinner Kit” or “Beef Lasagna Meal.” Although the word “kit” is not required on the label, all labeling must clearly indicate that the product consists of individual components.

• Clarify that it does not apply to products produced under the retail exemption; 
• Clarify that kits labeled as a standardized product must meet the regulatory standard;

Although FSIS will no longer conduct mandatory inspection of the assembly of the kit product, the meat or poultry component of the kit remains under FSIS’ jurisdiction and, as such, is required to meet all applicable FSIS labeling requirements, including product standards described in 9 CFR 319 and 381 Subpart P. Labels for such kit products assembled without FSIS inspection are not required to be submitted to FSIS for approval.

• Clarify that uninspected kits placed into shipping containers must not bear the USDA legend on the shipping container.

FSIS Guideline on Kit Product Labeling (usda.gov)
FSIS Guideline on Kit Product Labeling
GUIDELINE ID
FSIS-GD-2021-0011
ISSUE DATE
September 2021

Replaces: July 2019 Version

This guideline contains information to assist meat and poultry establishments to comply with the inspection and labeling requirements for multi-component food kits that contain an inspected and labeled meat or poultry component. This guideline relates to FSIS labeling regulations in 9 CFR part 317 and 9 CFR 381 subpart N.
Disclaimer: The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.

Full Guideline