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What's in a Warning Letter? Not a Whole Lotta Love
Posted on October 05, 2017 by Chris Campbell

Led Zeppelin released Led Zeppelin II on Halloween of 1969, and the following year, "Whole Lotta Love" was released as the lead single for the record. Although an interpretation of the song's lyrics might not be appropriate for the Food Institute Blog, if you read anything on the internet yesterday morning, you might understandably believe it was an ode to the most important ingredient in granola.

Yes, you read that right. Here is a smattering of headlines we tracked the morning of Oct. 4:

  • "The FDA Concludes 'Love,' Despite Being Extremely Toxic, Is Not an Ingredient" - from Gizmodo
  • "Joyless Feds Order Bakery to Stop Pretending 'Love' Is a Real Granola Ingredient" - from Grub Street
  • "A bakery listed 'love' in the ingredients. The food cops had something to say about it" - from Miami Herald
  • "FDA doesn’t want granola to be made with love" - from MarketWatch

The headlines stem from a Sept. 22 warning letter sent from FDA to Nashoba Brook Bakery LLC, located in Concord, MA. In the lengthy letter, FDA noted many violations of the Current Good Manufacturing Practice (CGMP) regulation for foods after an inspection in May. The major offense, according to these news organizations?

Your Nashoba Granola label lists ingredient "Love". Ingredients required to be declared on the label or labeling of food must be listed by their common or usual name [21 CFR 101.4(a)(1). "Love" is not a common or usual name of an ingredient, and is considered to be intervening material because it is not part of the common or usual name of the ingredient.

While I won't debate the merits of including or excluding love from a list of ingredients, I will tell you one thing: this wasn't the only issue FDA had with the bakery. The agency claims the company misbranded its Whole Wheat Bread product as it contains wheat flour and corn meal. They noted a number of bugs in the processing area. They noted unsanitary conditions for equipment and food products. They noted a potential for cross-contamination with peanuts.

To be fair, most of these pieces included the information about the other violations near the end of the story, and I can appreciate a great headline. But some of these seem somewhat disingenuous, considering the additional violations. I love "love" just as much as the next guy, but maybe a Whole Lotta Love is too much.

To their credit, Nashoba Brook Bakery LLC is working to address FDA's concerns. In addition, the company hopes to keep "love" as an ingredient, and they might be able to. CEO and co-founder John Gates said, "We just always took that as a nice signal to the consumer base as what kind of place we are. We don't take ourselves so seriously that we can't share the secret sauce. In order for the FDA to require that a food producer put a nutrition facts panel on the back of packaging, the producer has to make and sell more than 100,000 units of a particular product in a given year... We don't make that much granola," reported Washington Examiner (Oct. 4).

 

About the Author

Chris Campbell
Business Writer
The Food Institute

Chris focuses on fresh, canned and frozen fruit and fresh and dried vegetables for the Food Institute Report. In addition, he assists in compiling data for various Food Institute publications throughout the year. He is a proud Rutgers University alumnus with a degree in English, and has a background in web writing for a variety of industries, including legal, foodservice and small-to-medium sized businesses. In his downtime you can find him watching New York Yankees baseball, hiking, enjoying live music and spending time with his dog Kaiden. He invites you to contact him via email at chris.campbell@foodinstitute.com to talk about anything food-related.

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