4 Keys to Successful Quality & Food Safety Communications
Nutritional claims and Q&FS needs affect more than just packaging and production. When set up and communicated properly, they move project timelines and other departments forward more efficiently and create a smoother launch.
Rebecca Harter, our regulatory expert, and Rebecca Abreu, our food safety specialist, provide real-world examples and practical advice on handling your brand’s necessary Q&FS communication strategies.
Productive Cross-Functional Team Meetings
We’ve said it before, and we’ll say it again – cross functional teams and proactive communication are key to business success. Here are just a few examples of teams working together based on early nutrition claims identification and food safety boundaries given by Q&FS and Regulatory team members:
Sales & Product Development: If your brand’s objective is to be on shelf at Whole Foods, Sprouts, etc., the product development team needs to formulate with these retailers’ special requirements in mind, ensuring that the sales team can effectively pitch the final product.
Operations & Product Development: Once ingredients and suppliers have been established, the Q&FS team will advise the appropriate precautions to keep in mind when searching for a co-manufacturer. Is your desired coman facility able to work with your desired claims and certifications? It’s much cleaner to find a good fit early on, otherwise you may have to negotiate new safety protocols, change brand claims, or switch comans all together.
Packaging & Marketing: Time and money could be wasted if your brand needs to redesign packaging, repackage mislabeled product, or reorder promotional materials. If you’re a brand boasting sustainability and green initiatives who has to throw out a mislabeled packaging order, you now have unnecessary waste on your books.
Product Development & Regulatory: Our regulatory experts send clients a full spreadsheet on the nutritional contribution of every ingredient. For example, if you’re close to claiming a good source of protein, this spreadsheet can assist the development team in making changes to achieve this target.
Effective Coman & Brand Communication
How can you productively work with your coman to ensure their quality and allergen control programs meet industry standards, assuring accurate product claims and reduce risk of recall?
Research, prepare and control what you can to mitigate risk. Last month, we discussed acceptable risk. There is some risk involved with allowing anyone besides a regulatory expert create your nutritional label and claims. Harter has seen mislabeled products due to food engineers and comans having the best intentions but lacking nuanced regulatory knowledge, failing to adjust ounces to fluid ounces, using rounded data to calculate final claims, the list goes on. When a team brings in a regulatory expert early, they can spot these errors before a packaging order is placed or product is packaged.
“A lot of people will not be relentless in getting the best nutrition data from suppliers to create a true NFP. Good input will yield good output.” Harter states.
Mutual understanding will also set your production run for success. Abreu explains that most coman decisions boil down to cost effectiveness, amount of effort, length of downtime, schedule fit, and priority of customers.
“Asking questions to understand your coman’s approach can help close the gap between how they currently operate and the level you’d prefer.” says Abreu. “You must have tact. If the gap is significant, you approach the situation differently then if the gap is a ‘nice to have’. So ask the probing questions, have you thought about this or that, and they probably have a perfectly good answer as to why or why not this has worked in their facility in the past.”
Clear Customer Expectations
There’s a level of flexibility regarding the words, claims, and inferences a brand can make on their packaging and promotions. Some words are friendlier to the public eye while still being transparent with a customer – but there is a line between appeal and misleading a customer.
“Words carry a LOT of power. It’s a case-by-case basis and you cannot inappropriately persuade someone to think that your product has a health halo around it when it does not.” Harter reminds us also that “websites are held to the same scrutiny and standards as labeling on pack.”
Similar to a coman’s business decisions, your brand will choose paths thinking of the costs to attain a certain claim. For example, a company we worked with can say that their products are made in a Kosher certified facility. The product itself is not Kosher since that claim was too expensive for the business's current stage. Once they grow, they plan to certify and attain the Kosher symbol on their packaging.
If a labeling mistake is caught after a product is run, occasionally it can still be used. On a past project, Abreu found an acceptable solution to safely communicate allergens found in a finished product due to improper cleaning between skus. This company wanted to donate the product since it did not meet the standard for shelf.
“It’s not that easy. Just because it’s free doesn’t mean an allergic person won’t go into anaphylactic shock. We had the company sticker every package with a label saying ‘contains cashews’, and now the company can donate these in good faith.” Abreu explains that a big part of her job involves training up the brand and the coman to creatively think through issues, finding effective solutions that work for everyone.
Fruitful Q&FS and Regulatory Expert Conversations
Gathering information for a conversation with Q&FS and Regulatory experts is an effective way to keep your project moving forward. These experts already know the amount of research, time, and money to make a specific claim or set up a correct control program, but they need your business goals to offer the best advice.
“Come with your formula, a list of the claims you want to make, and an open mind. Sometimes when people learn all the regulatory work that goes into a protein claim, for example, they find out they don’t have enough high-quality protein and need a plan b. So, is there an alternate claim or something else that we can say instead?” Harter explains.
“You need to know the risk you’re willing to take. What’s negotiable and what’s non-negotiable? I’ll present possible solutions to a company and sometimes they make the decision I would and sometimes they don’t agree.” Abreu explains, “I can’t take the risk away, but I can help them make an educated decision based on a more complete picture.”
Be upfront about your budget. Abreu says that she can usually work with a brand to create a cost-conscious solution. “You don’t want a company to spend money on a program just to check a box. Let’s work to spend money on something that’s going to make your brand better and increase customer value.”
Gather claims, documentation, etc. into one easy-to-find spot. In case your product is challenged by a consumer or competitor, you have the resources at hand for a prompt response. It can also be helpful for conversations with PR companies, as they want to know what they can say and not say when speaking about your product. Additionally, good regulatory work and being ‘buttoned up’ makes your brand more attractive to investors, if that’s your goal, which leads to our final point.
Know your end goal so an expert can best strategize with you. Do you want to be bought out by a larger company? Transparency is legally needed and encouraged by our team, but there isn’t a need to give your ‘secret sauce’ away.
“There are things you can legally say in your ingredient statement that can protect your intellectual property. If you want to tout having seven spices in your formula, great, but I’d encourage a solution to put spice blend or another acceptable term on your ingredient statement. Then boast that you include seven spices as part of your marketing copy.” Harter agrees that customers crave transparency, “but if you list every spice in your formulation, a larger company could take your ingredient list and attempt to duplicate your work. Don’t be so transparent that someone can copy your entire business plan.”