Jam Label Non-Compliance Before Dispatch
A woman-owned unit in Birbhum makes 500 g glass jars of mixed fruit jam under an FSSAI state licence. The current label reads: 'Mixed Fruit Jam - contains mango pulp, papaya pulp, sugar, citric acid, pectin, permitted class II preservative'; net quantity 500 g; 'Store in a cool, dry place'; batch no. 114; MRP ₹120. The FSSAI licence number is printed in 6-point grey text on a gold background and is barely legible. There is no best-before date, no nutrition declaration, no veg/non-veg logo and no allergen statement. The laboratory reports TSS 65°Brix, pH 3.4, fruit pulp 45%, yeast and mould below 10 CFU/g; the product is safe. The unit has an order from a Jaipur distributor for 2,000 jars. The owner wants to print a new label with 'best before 12 months from packing', paste it over the old labels by hand and dispatch the existing stock.
1. Identify the mandatory label deficiencies and decide whether the batch can be dispatched with hand-pasted over-labels.
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Deficiencies: no best-before/use-by date, no nutrition declaration, no veg/non-veg logo, no legible FSSAI licence number, and no allergen statement. The licence number must be legible. Hand-pasting a new label over the old one is not acceptable for dispatch: it can obscure mandatory information, is not a controlled label change, and the best-before date cannot simply be added after the product was packed. The batch should be held, and relabelled only under a documented correction approved by the licence holder, with the true packing date; otherwise it should not be dispatched.
2. Using the analytical data, assess whether the jam meets the expected fruit-product standard and can support a 12-month best-before date. State two process controls for the next batch.
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TSS 65°Brix meets the minimum commonly specified for jam, pH 3.4 is well below 4.2 and gives an acid barrier, fruit pulp 45% meets the usual minimum, and yeast/mould below 10 CFU/g indicates good hygiene. These data support microbiological stability, but they do not by themselves prove a 12-month shelf life: glass-jar vacuum, headspace, seal integrity and storage temperature matter. A 12-month date should be supported by stability data or a documented shelf-life rationale. Controls: check TSS and pH on every batch; verify jar sealing/vacuum and fill temperature; retain samples for shelf-life checks.
3. What records should be kept for this batch, and how would you handle the 2,000-jar order if the labels cannot be corrected before the dispatch date?
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Keep batch production records, analytical results, label approval, packing date, licence copy, and distribution records showing lot, quantity and buyer. If labels cannot be corrected, do not dispatch. Inform the distributor, hold the stock and re-label it under a controlled procedure with a new label and a valid best-before based on the actual packing date. If any stock has already moved, initiate a traceability and recall check. The decision should be recorded so that the unit can show due diligence during an inspection.