Episode 4: Nutrition and Supplement Label Creation - From Lab Work to Software

[Music] Welcome to Food Products FAQ, a podcast where we discuss how you make food products in the steps it takes to make yours. I'm Adam Yee, and I'm Brent Chow. And we're both independent food consultants who've been through the food industry for over a decade, and we're here to share with you how we make great food products that have been sold at thousands of stores. Welcome to what is episode four? Yeah. Nutrition Label, Supplement Label Creations. Regulatory review. [Laughter] Yeah, so this is um. I don't know, would you call this an exciting part of food for our development? I think some people really like it, some people don't. Yeah, it depends. It's interesting. I think for people who love to do remote work, there's a lot on. Like this is remote work, haven't. Like you can just work anywhere and type away, create labels, look over labels. You do not have to be physically present to do any of this. Hmm, I see. Yeah, it's mostly doctrine collection, and then putting into an Excel or an Excel like program to. calculate out certain numbers that appear on your nutrition panel. Yep. So let's go to review back in episode one, right? It's so long. Was that was it too? No, it was it too. Wrong and clear of the story. It's too bad. Yeah, we kind of went a little bit into the nutrition facts or the. What do you call it? The spec sheets and the COA. Yeah, but there's like a specific. There's this vivid document for this, right? It's just called "intritional". That's what I easy ask for. Yeah, I ask for 100 gram nutritional specifically. If it's not part of the spec sheets, I ask to say include the 100 gram nutritionals. This gives us a very broad overview of. Out of 100 grams, you can translate that easily into a percentage and extrapolate that information into that ingredient that you're using. And you just multiply it up by the percentage of usage. So let's say out of 100 grams, you're only using, say, 2% of salt, for example. Well, you're only using 2 grams of that salt if it's a 100 gram batch. Yeah, but salt is not all sodium, right? It's also. So you have to divide that. Or you have to multiply that by a ratio of sodium and chloride, which, you know, I always. That was a kind of a trick I learned. I found it really interesting. Yeah, and there's a lot of different sea salts, iodized, iodized salts. And so you're getting a lot more than just your sodium and chloride nowadays. You're looking at potassium, you're looking at calcium, iodine, and other types of minerals. So there's a lot that goes into sea salts now, or even colorful salts. Yeah, the good news is that the 100 gram nutritional will tell you the amount of sodium that you can just plug and plant to your formula. So the thing I always like to talk about with 100 gram nutritional is, an example I usually give, is way protein, or any type of protein, specifically a concentrated or an isolate. So let's say you have a way protein concentrated, like 70%, because not all of it's 100%. You get the nutritional, you see that this is around 70 grams. And it's always going to give you, like, this range, or. No, they're always going to give you a minimum or a maximum depending on what they want to target. You can use that, or you can use the pure 100 gram nutritional, which has gone through rigorous amounts of testing to average out the amount of protein that there actually is. Or at least has the minimum amount, it's required on that label. So let's say a 70% way protein isolate, you'll have the 70 grams. And then let's say you're using 13 grams of way protein. What you're going to do is multiply 70 grams of way protein by 13% to get the amount of protein you're using for that way protein in your formula. That makes sense, Brian. That does make sense. I think for people who are more visual learners, essentially, when you work with us, you'll see an Excel sheet. And essentially the percentages are going to multiply out by every single nutritional attribute, whether it's a macro, a micro or bioactive compound and things of that nature. And so essentially you'll see all the numbers. And you'll be able to see how the math actually works out. It's very simple. One multiplies another to get you an end result. Yes. You can all do this in a formula through Excel. But there are many other ways and many other programs to do this. Let's just really break down a nutrition facts panel. And specifically, we're going to start with the food product, but we'll also touch on some other products. But a lot of it is what you see is what you get, which is great. So when you pick up a food product, you're always going to see nutrition facts panel. And then you're always going to see, well, I just go down a list. You know, it's service per container, serving size, calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrates, dietary fiber, total sugars, added sugars, protein. Those are your main macro molecules in your formula. Then you have these kind of these micro molecules as well, which are vitamin D, calcium, iron, and potassium. At least that's that's our label. I think some people do it a little bit differently, but that's generally legally what you have to put on. Yeah, specifically for food and beverages within the United States. If you're out in Canada, there's like slight nuances in the micronutrients that are required. They don't need the added sugars in things of that nature. And they do need dual language in both English and in French. So there's nuances depending on the way you want to sell the particular product or final product that you're pushing into in terms of the country of origin. Basically when you ask for a nutrition facts panel or a hundred gram nutritional, especially an ingredient company, they're going to give you a whole list of stuff. You don't have to put every single thing on there. I mean, those they'll give you things like magnesium, like molybdenum. I don't even know why they do that. You know why? It depends on the overall use case. So if you're looking at say a full meal replacement type of bar or shake, they want to list out as many of the micronutrients as possible. Because they want to make their particular product more complete. And so if you're looking through that lens out of a hundred gram nutritional, look at every single micronutrient is useful for those type of applications or those type of clients. And those type of clients would pay well significantly well so that it justifies the cost. Yeah, and I would say that, you know, what's great about a nutrition facts panel is that they're publicly displayed. So any product will have this. And if you do like competitive analysis, for instance, I find it wise to look at that first so we can understand not only the macros, but the micro they put on it. Yeah, so if you look at a nutrition label and both you and I Adam are able to take a look in kind of reverse engineer very high level from the nutrition label into the concept or a basic formulation, if you will. And so given that context, we're able to take a look at how much protein and kind of reverse engineer not exactly, but a rough range, a rough estimate of a working formulation, if you will. Yeah, so I guess when you deal with supplements, do you have a different approach than dealing with food. It's lately, I think there's there's a recent client that wanted to do a night tonic powder blend and essentially they want to call it a popular. Yeah, it is a lot of people want to have better rest and not just rest, but rejuvenation and things of that nature as well. And some of that is looking into the magnesium levels, some of that is looking into zinc, some of that is looking to adaptogens, antioxidants, low sugar, basically a well rounded type of product that is palatable to drink in this particular case, but also kind of promotes a good rest if you will, good sleep, good night sleep. And in that context, they wanted to put themselves as functional food. So functional food is very different than or food in beverage is very different that supplements supplements is more of like under broad category of drugs that doesn't have to necessarily go through clinical trials or anything of that nature. It's a pretty wild, wild west if you're going to supplements side of things. When you're classifying a particular label, you want to be able to understand if it's a food first ingredients or if it's more chemicals or bioactive is what we typically call that in the supplement space that's very forward. That means is if you're taking a tablet, a pill, a gummy bear, chocolate, whatever. However, the particular form factor is, if it's exceeding that amount of daily value or any type of food, then that specific purpose is a supplement. Now if it's more food-focused, you typically will see food ingredients first, spice and seasonings first, as like the number one, number two, number three type of ingredients. And then trailing behind it are the functional benefits of these other ingredients that are more functional in terms of added fibers, micronutrients, as well as any other promoters of sleep in this particular context. So it's basically looking at where is the natural derivative and the overall usage of this particular form factor. If you're taking a pill, that's not necessarily a food, and it's highly concentrated of some sort of extract. And then another thing is determining if that particular ingredient is generally recognized as safe. So grass denotion essentially is either FDA approved, which is a lot of money to do so from a company standpoint, an ingredient, company standpoint. As approved from the company itself, essentially needs some sort of scientific body of evidence of white paper testimonials and his of that nature to kind of validate. That can circumnavigate the FDA approval process, or grass could be from a third party that is approved. And this is typically seen more in the flavors realm of things, where you have a fema, which is the flavor association or body that will be able to have a third party board of scientists and lawyers basically look over and say if this is grass or not. And if you don't decide to do grass under the supplement division, it's actually okay. I mean, it's basically you're taking smaller doses of this particular ingredient or product or supplement, if you will. Okay, so whatever you found to be more difficult, like food, functional food or supplements, or does it not matter? I don't think it matters. I think it's really going and speaking with the brand owners and figuring out how to position the products on the shelf. And whether or not they want to lead with food ingredients first, or if they want to have exorbitantly high amount of molybidum or other types of bioactive or micronutrients, I think that's the hardest part is where do you position the product first? Because that means changing a nutrition label that people may not want to have in the first place. I think that's the harder part because creating the label is the easiest part. That's true. I mean, it's facts, right? The label is fortunately or facts. And I guess let's kind of dive in about how we do it. It is basically a giant proportions spreadsheet, right? This is literal what it is. You have your formula, which we discussed back in the days of episode one. And then you have these numbers based off the 100-gradient nutritionals, and then you do some weird magic to essentially spit out nutritional fact. It's kind of diving to the basics of how we do that and kind of the core about how that's done. Yeah, it's just imagine Excel sheet. What do you do? Sometimes I use an Excel sheet, right? Yeah. And you look at all the difference, ingredients, the percentages that make up your formulation that up to 100%, or 99.99% or 100, or 100, or 100, or 100%. And basically every single ingredient will have its own 100-grad nutritional. So if you continue down that row, you can list out the calories, the macronutrients, which are your fats, your sugars, or carbs in general, and your proteins. And then everything else would be a micronutrient. And if it's in the supplement side of things, you're looking at specifically what you want to list out as your bioactive ingredient. Essentially, you just multiply those altogether. Yeah, how I usually do it, and again, this is something you can do on your own. It's, it's, no, thanks not a lot of the figure out, but especially the two stars I founded where we couldn't really use the resources for lack of a better term to buy nutritional software. I would use Excel. And what I would do is I would have a library of ingredients that would have the 100 nutritional is all in a row. And then the next sheet, I would put the formula, and then I would use some type of macro or Excel formula to spit out a label for me. So that requires a lot of manual work. But, tragically, you still have to do this manual work when you work with the nutritional software anyways. I think there's new technologies that allow software to scan a document. But generally, traditionally, it's always been manually typed into some type of program in Excel's no exception. Yeah, essentially, that's a lot of our work is filling in some sort of whether it's an Excel sheet or some sort of software. It's a lot of data entry. And then the algorithms that are being set up allows you to get some sort of nutrition label at the end of the day. Even though you can use Excel, there's a lot of room for errors with Excel. Right? Like, there can be one small little number off and you can change everything. And you might not know where to find it. This is why these software, there's a specific software that helps with this. It also gets kind of this stamp of legitimacy, I feel, whenever, and this is really good branding on their part. But the stamp of legitimacy, when you use a nutritional software program, what do you call the exact term, do you know? I think it's, there's a database of sorts, a nutritional database, I think. Mm-hmm, yeah. And so I think we can segue to one of the most common ones, which is Genesis/Eisha. So what I use in college, they would, they would switch between the two brand names, E-shell or Genesis. And I was really confused which one was which until a later in my career. Yeah, that's the old school approach. And if you actually use the program, typically that's a larger corporation that has bought into the program in of itself, that is very old school. Like the UX UI on that is back in the-- Yeah, it's very old. Like Windows. Yeah, it's, so yeah, a little background on E-shell though, or Genesis, whatever you want to call it. This is a very expensive program. And I think from what I've heard in the grapevine has gotten worse because private equity bought it out and has been charging an arm and a leg for it. So it's this, but I will say a lot of people still use it, especially in the manufacturing realm where they can kind of afford it. A lot of my co-packers specifically here, my contract manufacturers, use Genesis quite often to validate a form. And that's because the factories are kind of either old school or they hear it word in mouth. I do actually think Genesis still has a hugely powerful brand associated with it when it comes to this specific nutritional software database. And if you do find out about it, one you'll be shocked about the UI, yes. I also think that it is still quite common to do. However, I do think recently it's been changing because they've been kind of messing up a little bit. Mainly the price increases, I think, are really, really straining consumers. So people are looking for other options. And Brian, have you tested a few of these? Yes, I've tested out flavor studios. That's what I'm currently using. I've also tested out Enter Technologies. They're augmenting by adding AI. So they're actually one of the companies that are trying to do those scanning, electronic scanning and actually those scanned documents will automatically upload into their database, the actual numbers. I'm sorry about flavor studio. I actually went to the Founders' House, delivery dumplings to him when we did our marketing campaign for our sellable foods. So I've been to his house. I haven't actually used flavor studio, Sham on me. I've heard a lot of great things about it, specifically I think from Matt's and which switched over. And so great job, Greg. Yeah. Shout out to Greg, who does flavor studios. He offers a pretty good deal. I think it's like 10X less than that of Genesis and he terms of price point. And it's just more than the nutrition or supplement label creation. He expands even further into, you can do a pricing model in that same platform, if you will. You can do ideation and sensory evaluation, which I haven't necessarily used. And also pairs with the CRM and project management, account management system, which I have not either used any of those functions. And also shout out to Chelsea over at Enter Technologies because they're a new player in the game and they're trying to add in AI and they're trying to figure out. how to streamline the process of making it just easier in terms of data entry, making it easier for people to get nutrition and supplement labels. So there's a lot of new competitors that are trying to enter into this space as well. Just do your proper due diligence, go over and look at the demos, look at do you need these extra functions? Fundamentally, what are you looking for in a nutrition label creation platform is to save you time and to minimize the amount of risk. And so essentially, do you have that budget to save time? You just need to cross compare how many ingredients or products you're trying to launch. I think it's where you need to start first. So funny thing about Enter, I think they paid me like 200 bucks to evaluate their AI program because their UI looks very familiar. They're kind of like a, I think it was a blind kind of evaluation. So they took out all the branding, but it was, they show me the capabilities. You know, it's unfortunately just chat TPPT and a wrapper, which you know, for some, it might be useful for some of my not be. But there are a lot of new players. And when I want to, it's due to food technologies, which is like the the the mecca of food science nerds. A lot of the new startups were nutritional software companies. This is a, this is a growing field that people are trying to figure out. When you boil down the basics of what we're trying to do for nutrition labels, it is pretty easy to figure this out using software. I've tested a few. Why don't I recommend is skew safe, which is pretty new as well. I think they're, they're kind of competitors to enter. There are so many some specific specifying baking, some specify and just a variety of other things. So there are a lot of them out there. They all probably pretty much do the same thing, honestly, right? Like they're all just an Excel sheet or a database aggregator. I think what is useful for some of these ones is the new USDA plug-in, right? What do you call it? Like they plug in the USDA database. So the USDA specifically has all of the common ingredients you could ever think of in their database, which they had tested hundreds of hundreds of times, which you can use to kind of just scratch formula. You can you can use you can pull out something there and let's say flour for instance. And it's just a general flour, but it does a good enough job of you defining what you want to make. And you can get more specific once you get the actual spec sheet from the actual flour you want to use. But generally I found great use in the USDA database. One is connected to a nutritional software. Definitely, definitely. I mean the USDA database essentially allows you to understand concepts and the nutritional parameters around the concepts first. And then once you get into the granular details when finding the appropriate supplier of the ingredients and the spec sheets associated with it, then you can actually be more specific and be more accurate in a nutrition label. And so I think that is a great way to kind of look at things from both a if you have the budget and you want to do it yourself. Great. If you don't have the budget and hard of the time, you can outsource to consultants that can actually create the labels for you. It really overall depends on what the project scope of work is. Is it strictly I just need a nutrition label. I don't have the time. Then you just essentially hire somebody else to do that. If you are basically looking for a very hands-off approach in both R&D sourcing nutrition labels, kind of a turnkey full sweep of services, if you will, then essentially that's kind of what you want in a package deal. And you're hoping that that particular consultant has a method to create their own nutrition label or they're using one of these software systems. And if you're much larger, then you can opt for a software system yourself. Yeah, I would say also I'd recommend register dieticians as a way to validate nutritionals because I think their course curriculum actually has them use this software or has them really figure that out. And if you have no way of contacting any label experts which there are honestly a ton of people who do this, then contact your local registered dietician because they'll definitely not do it. And you know, speaking of third parties, let's kind of talk about that a little bit. Specifically third parties can do this, they can formulate, they can gather specgies and they can make nutrition labels for you, but they can also do a lot more, specifically the lab portions of it. And there's a lot of them, right? So Eurofins for instance, or locally in San Francisco, there's Enresco, there are a few other ones. I think National Food Lab does it too, but I think they might have pivoted who knows. But after all, there are mergers and acquisitions that have happens with National Food Lab. Yeah, it's a question. I don't, I don't even know what they do anymore. So a lot of these laboratories do have actual analytical equipment that they can distill and analyze a single macromolecule or even a micromolecule. And they have really special lab equipment that we find is useful in summary guards. And so I guess the question is like, why would we go to a lab with all this fancy lab equipment for a food product? It depends on who you are as a brand. If you're an ingredient company and you're creating a novel ingredient in of itself, you essentially want to go through this whole process and work with the lab so that you know exactly how to get your 100 gram nutritional. So you can offer it to product developers brands and things of that nature. So I think that's that's where it's a core competency is if you are offering a new ingredients or you are a new company that offers a single ingredient that may not have the 100 gram nutritional in the first place. So that's that's an eternal investment because that's a tool that helps incorporate your particular ingredient in multiple formulations. If you are creating a product that's let's say novel in of itself the whole plant-based movement where you're looking into or even precision fermentation, if you're creating completely novel form factors or ingredients of proteins at these of that nature, you want to actually send this to a lab and make sure you have a very accurate reading of your nutritional. Excuse me. Like for example, perfect day when they are creating their way proteins, it's pretty complete and so it's a very different in what way in casing proteins that they have from the fermentation process. It's just a stop to there for people who don't know perfect day is they they make it from yeast cells, right? They produce it in a giant bioreactor, right? Yeah, they have genetically modified microbes that essentially creates the way protein and casings in a lab in a bioreactor exactly and so that's a more pure protein than trying to extract that or hydrolyze from dairy production. And then I think the third is if you're more in the food service realm of things, sometimes if you're just cooking things and you're getting raw material like lettuce, tomatoes, etc. that's not necessarily defined because the yield every single year could be very different. That's where you actually want to go to a lab and say let's actually be more specific in terms of where we want to get our nutritional stip. Yeah, and I think you do multiple tests on these two because you want an average of all this because if you do want to and done it may not be useful. It might it want to be a flip, but I think it's something to realize food is biological and therefore as it can have ranges and it's important to really understand that because though I think when you make a product you have more control over it, the raw material food is generally varies a lot depending on the season, depending on the type, depending on location is grown and all that. I kind of want to focus in on specifically CPG products in nutritional labs and how I've usually done it with labs like let's say an rescue in serumsisco is validation to make sure that my math is correct for the nutritional calculation and what I usually do is I ask for approximate analysis and what approximate analysis specifically is is the base like five macromolecules, so you know the base calories, toll fat, carbohydrates, protein and then generally I can go a little bit more specific by asking for a dietary fiber test and a sodium test for the products that I think are important. And I think it's just specific to know that your food product will have certain attributes that are very important for the consumer for so about dumplings, specifically the plant based dumplings, sodium and protein were very important to us and fiber in some extent was important to us as well. And calculating that out is pretty important just to validate that we're on the right track, specifically when you do claims and when you get into claims like high protein claims, this becomes extremely important. And I always recommend this is like one of three hundred dollar test. I always it this is like not a lot of money for a good amount of validation. because they will put this, they will literally tear your product apart and scan it through their equipment to give you an accurate number. Definitely. Yeah, I recommend this, or I actively recommend this when you have manufactured the products. At that point, you already have your golden standard, it's already produced, and then essentially you have a window in which you're testing your products. And at that same window, you want to actually make sure that your claims are accurate. You have a kind of a grace period when you launch the product as the first launch isn't necessarily the most accurate when you have a nutrition label. And the FDA already understands that in the context that you do anticipate some sort of change when you're commercializing a product. There's some minute details that needs to be changed. You can't just change the label on site. It takes at least a month of looking at the entire packaging, making sure it's regulatory approved for that time being. And then as you go into your first production run, the actual production run outside of commercialization trials, that's when you want to have everything kind of tidy up. And so there are, for a better or for worse, there are lawyers. It's a very litigious society that we live in that all they do is look for any small detail and they'll find a way to sue you. And it's a shame. There's a lot of small medium business owners, there's a lot of startups that don't have the money, they don't have the time, or the luxury to defend themselves against these lawyers that understand the law inside and out. And so I think for all intents and purposes, it's our due diligence or hiring a regulatory affairs slash lawyer to really give a final look over and saying, yeah, this is good. This is in accordance to the FDA. This is in accordance to how you want to label things, including your sub-ingredients. And also how you look at the font size or the layout of the nutrition or supplement facts. That's actually pretty important too. Yeah, I always, when we get the label underway, I always send it to a labeling expert to just validate it. It's always great to have a third party to understand what's going on. Though we can be experts, and we might be that person who validates, but I recommend Denise Webster from, not sure where she's in the SCS, I think, she just signed a paper for me, which is funny. But she's really a really spot on, not only great at validating ingredient documents, but also nutritional libles as well. So there are people who do this. For litigation specifically, this is pretty important, though it only happens when you are a big company, I would say, or at least have a viral spike. I think one example is Lenny's and Larry's got caught having a low approaching amount for their protein cookies. La Croix got caught saying that they use, well, at some type of, like, quote, natural flavor and they use natural flavor, but then the lawyers kind of dug into that a little bit more. And poppy, I think recently got litigated because they mentioned about gut health in their drinks. So why don't I use a true and this happens, and there are literally lawyers whose jobs there is to literally pick up a product, scan it, and try and find out what's wrong with it. And generally this happens when your product becomes more popular. So just an FYI. Yeah. Yeah. You have some leeway, especially if you're just launching the product for the first time. But if you've been around for 20 or so years, and you've been just kind of coasting, you're basically gambling every single day. And if it's a product recall, let's say you are in large presence and say a regional area, even the local, um, no FDA agent, if they find out, catch, when you may have a product recall where your packaging is wrong. And there's more recalls in packaging than there are recalls in a food safety matter. No, essentially, you want to be able to be ahead of the curve in that sense. That's not to say that you have to constantly look at your labels. It's more of let's make sure that you are doing it right for the first time so that you don't have to do it over and over again. Yes, indeed. I think, you know, they're very common things that you can miss in a label, right? Not only can you miss a food ingredient, but you can also miss allergens, right? Allegins are extremely important, especially I would say they're probably one of the most important things people track, specifically the government tracks it a lot. Like if you are, let's say, applying for a PFR in California, for instance, a processed food, what do you call it? Registration. Yeah, that's the word process food registration. Days specifically last for allergens, um, for your food product. So because, you know, if you feed someone a product, let's say you made something and had peanuts in it and you fed someone with a peanut allergy, it will probably send them to the hospital and then it kind of ruins your brand. So it's just like these things are important and packaging also. I don't know what we discussed this before, but packaging does have high MLQs, so you have to be very, very peculiar about that. A recall with packaging, specifically, you have to throw away pretty much all that stock when that happens, which can be, which can suck. Yeah, that's, it's a lot of work. I mean, you're, if you're going back to the episode about sourcing, we also have to consider not only the minimums, but what the lead times look like. Does it actually fit the machines in the right orientation where you're putting the label on, say, the bottles or the packaging in of itself, is the film going to actually work in the machines, whether it's from your own manufacturing or the contract manufacturer that you use. There's a lot of coordination and you're putting a lot of money down to basically have something that cannot be reworked that you cannot just, you know, doctor up or stick her up. It's very hard to make those changes and it impacts the brand first and foremost, because that's what people see. They don't see the food necessarily. I see the package. It's very important to actually understand all of that, both the inside and outside, but the functional usage of the package and how it allows for shelf stability, but also the, what the images are projected on the front of package as well as the nutrition fax panel on the back of a package and the story anywhere between. Yep. Speaking of stickering up, I have known some situations, especially in bigger manufacturing facilities where stickering up has been a more rational option in terms of changing the label after a recall. Early, it's like, you know, the stuff that's still in the factory for instance. So I always find that really, really interesting, just the decisions that can be made for that. But yeah, it's overall, it's just a costly thing not to have your package validated, but I will say that this happens much later in a food product cycle. If you're a small business, well, we found out, specifically, is that it is much easier. I think if you're sub-a-million revenue, it's much easier to, you, you, yes, I just won't be on people's radar pretty much. You won't be on the radar. You won't be on lawyers radar. For them, it's just not worth it. Does that mean you should detract on this? I don't think so. You should do some checks. You should do some, I specifically like the third party approach of scanning for just approximates. Again, it's relatively pretty cheap. And it will give you some data in the long run because basically what the best way to defend yourself for a lot of these things is having a paper trial and some documentation about saying that you've done your kind of due diligence and tested this out and all that. I think it can save you in the very long run if you start early. Yeah, you want to build in the good practices, the good habits so that you don't have to worry about this. One note to go back on allergens is that there are allergens in which some ingredients are, are allergens the top nine now in the United States that you list out. And then if you don't have any of the allergens, but the facility actually creates something that does have allergens, you do want to list that on the packaging that the facility also manufactures using eggs or milk or something of that nature. Legally speaking, there is no ramifications in terms of having to actually list out the allergens. Being able to do it out of their own PR and marketing and food safety approach. And that's what actually what you should do because the last thing you want is to have a bad PR where somebody gets sick or has an allergic reaction that's pretty severe that would cause pretty big devastation across the brand end of itself. And if it's a well-funded VC, then essentially the investors may want to pull back or change the dynamic of the corporation end of itself. Yeah, interesting. Yeah, at the end of the day, you are showing these products to the public, you are showing them the consumers and consumers want brands they can trust. And I think that's pretty important for a food product because from what I've understood in the industry is that people really do trust you when you put food in their mouth essentially, right? Like if It is the ultimate form of trust to eat something that you created. Whether it is a food product or in food service or even cooking at home, I think there's a huge amount of trust involved when it comes to that. Even though we don't think about it too often, there is this gigantic regulatory trust, but we also have individual brand trust as well that is important to emphasize or to appreciate. If you want to talk about serving sizes because I think that is something actually in college at this really funny story, we did a probably development competition and I was a freshman at the time and we were thinking of this freeze dried powder mix on yogurt thing and we were like, "Okay, how much is a serving of fruit?" Because we were trying to figure out that and we did not account that dried ingredients, you don't need that much to be serving a fruit and so we had these huge powder sticks. That was equal. He's a serving of fruit and I realized, less later on, he's like, "Wait, servings can be pretty flexible. Have you found that to be the case?" Yeah, there are companies where they ask me, "What's the serving size?" So I typically tell them that it ranges, you can't just make up a particular number. There are standards. You can try to take a look at what the large players are doing in terms of the serving sizes. You can also find that I think it was either the USD or FDA has a list of recommendations on serving sizes. If you go below the recommendation, that's typically taboo. If you go above the recommendation, that's not necessarily a problem. So essentially, you want to meet the recommendation or exceed the recommendation in terms of serving size. When you're looking at, say, bars, I think back in 2015 to 2017, bars, a lot of bars at the time were 45 grams. They're very small. The whole protein movements of increased protein came about where you're trying to fill as much protein inside a bar. So 45 grams were standard back then. It's very hard to actually be able to fit a lot of protein and actually have it taste very good. We're looking at now our 60 grams to 75 grams bars with a lot of protein, 20, 25 grams of protein per serving. There is adjustments based off of the actual demand or need of it. Eventually that is exceeding what was originally a 45 gram that the market or people have assumed to be a good serving size. Yeah, it was definitely a creep. I worked at the protein bar industry. We made 65 grams bars with 18 grams of protein I think. With now, people are putting more protein to more bars. I think now the newest innovation is David's protein bar, which is made by the founder of the bar X bar, Peter Rall. Let me just double check the nutritional here. One of the impressive things for that specifically is the amount of protein they put into a single serving bar and without the calorie load, which we know why that is. So 28 grams of protein in one bar that is pretty impressive. That's the leading amount of protein in a bar that I've seen. It's crazy how we go up and up and up in protein. Serving size, I think there are roles in a specific way that you're targeting too. It's also important. If you're doing school cafeterias or something like that becomes a lot more important than consumer package goods, generally though, we found Serving size is kind of all over the list. Even if you look at a competitive set of products, like let's say dumplings, for instance, you take like five different dumplings. Can you count a dumpling as an appetizer? Can you count as a meal? We count it as a meal. Therefore, we can improve the serving size. So we can improve the protein amount. It's all perception. The big one is that you can, I don't want to say manipulate serving size, but there are ways to weave in the story of your serving size to get kind of the message you want to put across for a syllable food specifically. We wanted to weave in protein amount, so we decided to go with let's say a meal serving size. For better meat codes for you chicken plus, they decided to go with a one fourth of veggies per cup as they're kind of call out. That justifies their serving size too. I actually would argue that your claims actually are a way to adjust your serving size. There are very nuanced ways of fitting your claims to fit your serving size. Yeah, so overall, whenever you speak with a consultant that knows food, beverage, and supplements in general, our common answer is depends. It depends on the category. It depends on the overall usage. Because again, when Adam, you're speaking about food service or even school systems, K through 12 school systems do require you, if you're talking about protein, to fill out a specific form that you have to use say that Kelldall method or the nitrogen count and prove to them. This is the amount of protein that is a complete protein for kids nutrition. You need to have that kind of signed off too. Which probably requires a third party love to sense or nexus. So that yeah, it all connects in a way. I do think that serving size is, how can I say this? It is a very nuanced field. I will say it all, but also it's kind of straightforward, especially nowadays. They've kind of been fixing and tweaking how we communicate serving size. For example, a pint of ice cream used to be what, two tablespoons as a serving, but now they label as a full pint as a serving because people realistically eat a pint of ice cream for protein bars. It's not the best idea to put two servings in a bar. It's better to put one bar as one serving. So servings do have a realistic metric to it, but sometimes you can kind of stretch that metric a little bit. Yeah. To look at dual labels, this is more recent. It's to understand if you have say a snack that's between two to four servings in there, you do need to have that dual label. This is what a serving looks like, and this is what the full package looks like. So it also depends on how you package the entire product in of itself, if there's multiple servings in it in of itself. Another thing to look at is if you're creating sauces, hot sauce versus that of barbecue sauce or two different serving sizes, because how you use a hot sauce is more like a teaspoon, this is that of barbecue sauce. The very bare minimum is two tablespoons. If you're comparing yourself as a salsa, where does that land? So salsa's actually land a little bit more in the realm of barbecue sauces where it's two tablespoons. Now you can go above it, but if you try to go below, then that's where it becomes a zero sum game because a lot of if that's allowed, a lot of other competitors are going to start saying, well, then I'm going to use half a teaspoon and give you the bare minimum of nutrients conveyed to the consumer. And I think the zero sum game here comes in into play where it's like, well, why don't I just put 0.01 grams as a serving size and I'll have zero calories. So now you have a zero calorie salsa or something of that nature. So we say there's flexibility, but it doesn't mean you would be creative and going down to giving yourself the bare nutrients possible and say the snacks or candy side of things. So there is some recommendations that you should abide by. Otherwise, there are a lot of questions in how you're promoting your brand. Yeah. So, you know, we talked a lot about brand and promotion. These are technically regulatory rules, right? So we know that the FDA does post what a thing is on their website, right? There's a CFR 21, I believe that is it's a huge document. You know, there's an online stuff and it's decently easy to search, but it is can't can be a pain to look it up. And sometimes I think the rules are kind of vague for lack of editor or hard to interpret. What I'm trying to give here is that this is all out there on the internet. Like the FDA does have rules for almost every single food product, but do you have any advice for anyone who is either trying to get this information or is trying to interpret this information? Yeah, I think if you're trying to get the information, it's free, right? And I think with the onset of chat GPT and a lot of news out there, they are anticipated some sort of changes to regulation. So it's trying to keep up to date in that context. And I'm sure there's enough people that would be able to synthesize it for you. I think if you are bootstrapped, you're looking at accelerated programs, incubator programs, or even pro bono type of cases from lawyers or law students or law professors that specialize in this particular field. You get the benefit from the state or the city or the municipality. I said, that's the city, or the federal level, depending on how each of these cases are situated. So, you can definitely ask around. And I think that's the beauty of being an entrepreneur in general is you just ask. And then I'm sure there'd be some sort of insight. Is that going to save you some time? No, because you're learning yourself. If you want to hand it off to somebody, you do your due diligence to be able to understand where the regulatory affairs person is coming from, and you make the best judgment at the end of the day. Yeah, I'll add a few kind of other resources too, because I was in that scribe position more than once. And I asked a few different people as well. I think one specifically is competitors. You actually would be surprised who is open to helping you out in a competitive standpoint. We're kind of all in this together. And there's a playbook in most of these products. So if you're a hot sauce company, you can probably ask another hot sauce company for the service size or the rationale of that serving size. Another one is your contract manufacturer who has made tons of these different products most likely, or has a good idea about what to do this on. And they will have their opinion on what you would put as a serving size, or what to classify your product as. The client will say what they want to say in terms of that, but contract manufacturer is you'd be surprised. I mean, they definitely know what they're doing. And they definitely want to know what they're doing. Right. Yeah, the good ones know what they're doing. And that's true. I need to really clarify that. But also, if you really don't have anyone to ask, everything is right there in the grocery store for you. And if you are, I'll just say hot sauce company or salsa barbecue company, buy literally five different products like yours, like five different barbecue sauces from five different brands and compare them. And this is what we call competitive analysis in my book, but this tells you a lot of information in general about how you should. What are the gas missing in that category, but to what are the standard serving sizes they're doing for that category? And is it worth it to change it or not? That's up to you. And you should take a look at, I mean, if you don't have the funds to buy it, I mean, just sneak in your camera phone and take pictures of the people think it's a level all the time. I do it in the grocery store. And you know, I mean, you don't have to buy the product. If you buy the product, that makes it better that you have something on hand. And I think some people find it on on websites too. Yes. Like, I would say look towards the fortune 500 type companies because they've put a lot of money in legal and regulatory affairs to make sure this is done right. If it's another startup that you're comparing against, you're both in the same boat. So you both might be winging it together. And so that may not be a good comparison. That is true. So everyone, the great news is that there's examples all around you and just uses of utilize those resources correctly. The great news of nutritional labeling specifically is that it has to be out in the open. Yeah. Transparency for people. Mm-hmm, definitely. That's the beauty of the world we live in because there's a lot of history of that going wrong. All right. I think that's a great end to our episode about nutritional labeling. You know, we thought you some tricks. We thought you some programs. We thought you some of the insider information about how we kind of dissect and analyze these nutrients. And so I hope you enjoyed that. Definitely. I tune to it next time. Yep. Next time we're talking about commercialization. Take care, everyone. Welcome to Food Products FAQ, a podcast where you just, oh boy, so do you like a sleep. Welcome to Food Products.