As a baker are you thinking about restocking your packaging supplies? If you are, then you have a lot to think about before making the investment. The most important consideration is how long you will use the packaging. If you are going to run through it fairly quickly, then you should be good to go, but if you expect to have it around for a while, you need to carefully consider how much to buy.
Every week, it seems like a new government rule, guideline or proposal surfaces that will change your packages. Just last week, the new FDA rules for gluten-free labeling were finalized. While it will impact a narrow segment of the baking industry, it is a precursor of bigger things to come. The biggest of which are the proposed revisions to the Nutrition Facts Panel (NFP) that FDA is pushing hard to finalize. That doesn’t even take into consideration proposals on partially hydrogenated oils, sodium, front of package, GMOs, well you get the idea.
Substantively, the NFP proposal attempts to address several thorny issues such as added sugars, fiber, trans fats, sodium and vitamin D. However, the proposal also significantly alters the format and potentially the size of the current panel. Thus, regardless of the outcome of the substantive debate, there is a high likelihood of some change to the graphics themselves. The real challenge for bakers and their packaging suppliers is the two year implementation timeline for any changes, especially given the already existing packaging backlog. Given the pressure the White House is exerting on FDA to finalize the rule in the coming year, it will be incredibly difficult to expand the timeline.
Recognizing the significant cost and operational challenges a new NFP presents to the industry, ABA is leading a group of over 15 other food associations in insisting that FDA rely on sound, peer reviewed science to determine the substantive issues. The group also is asking for enough time, at least 3-5 years, to implement any changes while avoiding severe stress on the packaging supply chain. When the Nutrition Labeling Education Act (NLEA) passed in the 1990s, there were a third of the products on the market as there are today. Simple math ought to be convincing enough for FDA to grant as much flexibility as possible in order to avoid hundreds of millions of dollars of cost.
I would be remiss in not calling out the very significant contributions of the ABA FTRAC in formulating our extensive and incredibly substantive comments to FDA. Also, I would like to thank ABA’s packaging members for their invaluable assistance and the Retail Bakers of America for their support in this undertaking. While ABA’s comments are just the opening move in what is likely to be a protracted battle, our combined opening salvo was very strong because of the unified engagement.