1. When does the addition of the watermark “Copy not for documenting federal meal requirements” and removal of the inspection legend from CN product labels need to take place?
The watermark, is to be applied to all CN contribution statements not supported by product specific documentation and to CN product labels that are distributed without federally inspected and packaged product. According to the FSIS policy book, all USDA inspection legends are prohibited from use on anything except actual product or pictures of actual product regardless of the intended use of the product. For CN Labeling Program purposes, this applies to all federal (USDA & USDC) inspection legends.
2. What is meant by the term “copy”?
The term “copy” refers to any version of a product label that is distributed without product in the product carton. Providing copies of product labels without the packaged food creates the potential for circumventing the Food and Nutrition Service Quality Control Program requirements for CN Labeled products.
3. Can meat and poultry manufacturers distribute copies of federally regulated meat and poultry product labels with the inspection legend even if it does not have an authorized CN Label?
No. According to the FSIS policy book, all USDA inspection legends are prohibited from use on anything except actual product or pictures of actual product regardless of the intended use of the product. For CN Labeling Program purposes, this applies to all federal (USDA & USDC) inspection legends.
4. Is there a specific style that should be used when adding the watermark, “Copy not for documenting federal meal requirements” to samples of the CN product label without the inspection legend?
The watermark should be made obvious by placing it directly below the CN Logo & contribution statement in a font size that is substantially larger than the rest of the information on the product label. The following example is highly visible because the font size is not less than 24 point type using Times New Roman:
Copy not for documenting federal meal requirements
5. Which is preferred, removing or redacting the federal inspection legend?
Removal of the inspection legend is preferred. If you redact the legend, it should be completely blacked out.
For more information, please refer to the technical assistance policy memo titled, Guidance for Accepting Processed Product Documentation for Meal Pattern Requirements.
The contents of this guidance document do not have the force and effect of law and are not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.