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a Food Label that Declares "No MSG Added" is false and misleading
under section (403) (a) (1) of the Federal Food, Drug and Cosmetic Act
when the label also lists any hydrolyzed protein
as an ingredient because all hydrolyzed proteins contain MSG."
DEC 5 1991
Jack L. Samuels
Northfield, Illinois 60093
Dear Mr. Samuels:
A letter dated October 18, 1991, written to you by Joe K. Holloway of the Division of Regulatory Guidance has come to my attention. Mr. Holloway’s letter responded to your letter of August 12, 1991, to Dr. David Kessler, Commissioner of Food and Drugs, concerning the labeling of Sun-Bird Stir-Fry Oriental Seasoning Mix, distributed by S&B International Corporation, Torrance, California. Specifically, the label included the statement No MSG Added, however, hydrolyzed vegetable protein was listed in the ingredient statement for the product.
I regret that you were informed that this product label does not appear to violate labeling regulations. Such a statement is inconsistent with FDAs position that a food label that declares No MSG Added is false and misleading under section (403(a)(1) of the Federal Food, Drug, and Cosmetic Act when the label also lists any hydrolyzed protein as an ingredient since it contains MSG.
I have directed our Los Angles District to consider regulatory action against the Sun Bird product mentioned in your letter and any other product which is similarly labeled in a misleading manner.
I thank you for your continued interest in his important consumer matter. If
you have information concerning other labels that state No MSG but
contain hydrolyzed protein, please let us know.