What’s in a Warning Letter? Not a Whole Lotta Love

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 songs 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 MarketWatmagnesium citrate softgels nowchThe headlines stem from a Sept. 22 warning lecitracal calcium plus d3tter sent from FDA to Nashoba Brook Bakery LLC, located in Concord, MA. In the lengthy letter, FDA noted many violations of the Current Gliquid calcium magnesium citrate with vitamin d3ood 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 wont debate the merits of including or excluding love from a list of ingredients, I will tell you one thing: this wasnt 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 magnesium citrate near meheadline. 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 FDAs 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 dont take ourselves so seriously that we cant 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 solgar zinc citrate 30 mgthan 100,000 units of a particular product in a given year We dont make that much granola, reported Washington Examiner (Oct. 4).

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