FDA Letter to Brownie Manufacturer Serves as Reminder of Importance in Product Labeling

By Mike Rozembajgier

An recent warning from the Food and Drug Administration (FDA) provides an important reminder of the need for proper marketing and labeling of food products. The FDA recently sent a warning letter to HBB LLC about the package labeling of their Lazy Larry brownie product. The FDA’s action offers some helpful reminders to all food producers about the link between product marketing and consumer safety. If the improper marketing of Lazy Larry brownies had led to illness or injury, comprehensive recall management services would have likely been necessary.

As Packaging World reports, the FDA warned HBB LLC that its product was “represented for use as a conventional food, and accordingly is not a dietary supplement,” as the product packaging claimed. The FDA noted that while the ingredient melatonin is allowed in certain dietary supplements, the FDA’s classification of Lazy Larry brownies as food rather than a dietary supplement makes the presence of melatonin a violation of food safety rules.

The FDA’s warning letter noted that Lazy Larry brownies were in fact a food product since they are marketed alongside snack foods and claim to have the same ingredients as traditional brownies.  The FDA asked HBB to change the marketing of the product to more closely resemble other approved dietary supplements.  HBB LLC has agreed and is taking “immediate steps to address the concerns,” according to the Packaging World report.

This incident should serve as an example for every food producer of the importance of proper labeling and marketing. As companies continue to market their products to an increasingly health-conscious consumer base, they need to be careful to avoid FDA problems by understanding and complying with the specific terms and conditions that govern a product’s marketability.

Consumers concerned about a healthy, well-balanced diet are already sensitive about the ingredients in their food. Mislabeled or incorrectly marketed products containing improper ingredients may not only hurt sales, but may also cause illness.

A  Vanderbilt University study recommends people with “severe mental illness, severe allergies, auto-immune diseases or immune system cancers” not take melatonin.  Had someone with one of these conditions eaten a Lazy Larry brownie, expecting only the traditional brownie ingredients, the results could have been much more serious, and might have caused a product recall.

Beyond product safety, consumers expect food products to be properly labeled so they know what they are buying and feeding to their families.  This is a responsibility that should not be taken lightly, and it appears HBB LLC is responding accordingly.

As so-called “superfoods” and “nutraceuticals” that blur the line between food product and dietary supplements continue to gain traction in the marketplace, product manufacturers need to heed the FDA’s warnings to HBB LLC and remember always to package and market their products appropriately.  Consumers should be reminded to carefully review the labeling and ingredients in the foods they buy to ensure their own safety.

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