Although the requirements for both take effect on January 1, 2006, the food allergen requirements are based on the date of labeling while the trans fat requirements are based on the date of “initial introduction into interstate commerce.”
According to the associations, the difference could introduce complexities and uncertainty for companies in both labeling and distribution. Harmonizing the triggers will make the relabeling process more efficient. The request left it up to FDA to decide how best to do this.
