FDA Updates Import Alert 99-39: How Can Food Buyers Spot Labeling Errors Before Shipment?
Label reviews should link formulas, regulations, and batches instead of checking layout alone
Why labeling errors can directly affect customs clearance
The FDA updated Import Alert 99-39 on September 25. The alert covers imported foods that appear to be misbranded. For buyers, the risk goes beyond spelling mistakes. It can also involve inconsistent information about ingredients, allergens, net quantity, or the responsible business.
Key point: Buyers should review the final formula, supplier specifications, label artwork, and commercial documents together before releasing a shipment.
Four checks before shipment
| Step | What to check | Person responsible |
|---|---|---|
| 1 | Final formula and ingredient list | Supplier quality staff |
| 2 | Allergen and nutrition information | Regulatory or compliance staff |
| 3 | Net quantity, responsible business, and origin information | Importer |
| 4 | Shipping marks, invoices, and label version | Logistics and procurement staff |
Buyers should lock the print-ready file. Factories must not arrange printing from chat screenshots or old PDFs. They should photograph the first printed sample and compare it with the approved artwork item by item.
Scope and limits
Different food categories may have specific labeling rules. This article cannot replace a review of a particular formula and its claims by a U.S. regulatory adviser.
FAQ
1. Does the factory still have responsibilities if the U.S. buyer supplies the label?
The factory should still produce according to the approved version and report changes to the formula or materials.
2. Is checking only the retail packaging enough?
No. The outer cartons, invoices, and declaration information must also match.
3. When should the final label be locked?
The label should be locked after the formula and packaging are confirmed and before production printing begins.
What procurement teams can do now
Teams can assign a label version number and require each production batch to record the version actually used.
Stellar.shop content suggestion: Add fields for formula version, label version, approval date, and the first printed sample to food purchase orders.