It may come as a surprise to quality assurance personnel to know that there is a group of people who are eyeballing product labels almost as closely as they are: kosher consumers. Jewish dietary symbols are on the radar screen of this group, whose constituents will contact kosher agencies regarding any doubts about authenticity. And while otherwise well-run companies are quite adept at ensuring fidelity to seals of approval (gluten-free, organic, etc.,) ingredient and allergen statements, they might benefit from a few best practices with which to ensure the kosher compliance of labels, as well.
A FRUIT CANDY EXAMPLE. Here is a common consumer inquiry scenario which occurred not long ago at the Orthodox Union (OU) kosher certification agency. Names and details have been changed, but the lesson is true-to-life.
Mega-Mart, the retail consumer emporium, had been offering a bulk version of the popular confection, Organic Fruity Chews. It was made available in five fruit flavors, each a separate, packeted SKU, but packaged together in one large bag.
Recently, kosher certification had been terminated on this one product line, due to the shortage of organic grape juice. The manufacturer, The Sweet-But-Good Company, had searched world-wide for a supplier of organic grape juice concentrate that met product specifications. With no choice but to opt for a non-kosher-certified organic grape, the company had to terminate the kosher certification of its cherry and grape SKUs. In the end, to avoid consumer confusion, Sweet-But-Good opted to pull certification from the entire Fruit Chews product line: grape, cherry, orange — the works.
It was a Monday morning when the OU kosher consumer hotline’s computer blipped to attention: Abby Goldberg, a 30-something mother of three young, enthusiastic kosher-candy consumers, was on the line. “Hello. I’m confused as to whether Organic Fruity Chews are kosher-certified or not,” she says. “There is a kosher symbol on the outer wrapper of the bulk package I bought at Mega-Mart. But there isn’t a symbol on the inside packets.”
As the scenario repeats itself several times that morning, the hotline staff contacts Sweet-But-Good’s OU kosher account executive. The rabbi is hard-pressed to understand how the symbol got on the package by an otherwise professional and kosher-cooperative account.
Several calls later, it is determined that the graphics department at Sweet-But-Good had cut-and-pasted an old jpg file of several of the SKUs onto the film of the bulk container, as a sampling of what was inside. One of those SKUs happened to show the unmistakable OU kosher symbol.
Apparently, the graphics group was unaware of the presence of the kosher symbol on the old file — and perhaps not sufficiently aware of the concurrent lack of symbology on the product label itself.
Reflecting upon this story, Rabbi Gavriel Price, rabbinic coordinator and account executive at the OU’s New York headquarters, offered companies some advice. “The default status of finished products should be non-kosher, until active kosher certification is achieved,” he said. “This will prevent non-kosher products from being mislabeled as kosher, as was the case here.”
MIXED KOSHER LINES. There also is more than one permutation of kosher to be concerned about. OU companies receive a rider to their contract which stipulates the dairy or “pareve” (non-dairy) status of finished kosher products. Products that will bear a plain OU must be processed as pareve, while those with an OU-D symbol must be restricted to dairy lines or modes.
This is challenging, especially to companies operating mixed (kosher/non-kosher or kosher-dairy/kosher-pareve) plants, who will need to closely monitor the use of the OU/OU-D symbol on their labels.
Following is how one company handles a mixed kosher program. “All packaging goes through regulatory, and we review each label to make sure it’s correct,” said Nature’s Path Foods Regulatory Affairs Supervisor Sandy Cheung. The Richmond, BC, company produces organic snack food.
“We go through each ingredient’s kosher certification, checking its kosher specs for pareve or dairy status. Based on this, we provide either an OU or OU-D label for OU approval,” Cheung said.
Though far from the production line, graphics departments, too, need to keep tabs on kosher documents. They would be well-advised to treat kosher symbols with the same sensitivity with which they are trained to regard other professional icons — as protected trademarks which require confirmation prior to usage.
“The word ‘recall’ doesn’t have a D in it. Companies need to understand — that D is a very significant D,” said OU Senior Rabbinic Field Representative Rabbi Avrohom Stone.
“During product development and label finalization, someone needs to sign off that the symbols match the actual kosher certification,” he said.
To mitigate these details, one cannot underestimate the importance of assigning well-trained personnel as kosher contacts. “There is a lot riding on these decisions; no one wants to risk a recall by assigning a less-than-qualified person to this task,” said Rabbi Price.In the earlier Mega-Mart tale, the Sweet-But-Good graphics folks overlooked the errant symbol printed on the graphic. Those staffers could have reviewed that graphic with the same care as film that features other trademarks.
Fortunately, the story had a happy ending. The kosher symbol was depicted on the jpg of the orange-flavored SKU which was made under kosher conditions, though no longer formally certified. This scenario was deemed acceptable by the OU, and a product recall was avoided. And the story was a learning experience for all those involved in kosher labeling at Sweet-But-Good — and for every QA person: to monitor kosher compliance from raw material to finished, labeled product.
The author is the kosher coordinator of a roster of chemical and botanical companies at the OU.