The U.S. Food and Drug Administration (FDA) has released a major update to its general food labeling compliance program. The revised program, Compliance Program 7321.005, replaces the 2010 version and is now titled “General Food Labeling Requirements and Labeling-Related Sample Analysis — Domestic and Import.” It reflects the FDA’s current regulations, inspection priorities, and enforcement procedures.
Read the full FDA Compliance Program 7321.005 (PDF)
Key Updates in Compliance Program 7321.005
The updated program explains how FDA inspectors check food labels and test samples at U.S. and international facilities. Key updates include:
Sesame Added as a Major Allergen
The program includes the FASTER Act of 2021, which requires sesame to be clearly labeled as a major allergen. OU Kosher already monitors sesame use as part of its allergen controls.
Revised Gluten-Free Guidelines
Labels that claim “gluten-free” must meet strict FDA rules for safety. This is especially important for OU Kosher-certified Passover products and others that carry both gluten-free and kosher symbols.
Nutrition Facts Label Modernization
Changes include:
- Larger and clearer calorie and serving size information
- Added sugars listed separately
- New required nutrients (like vitamin D and potassium)
- Updated daily value amounts
More information is available in the FDA’s overview of changes to the Nutrition Facts label.
Clearer Rules for Sample Testing
Inspectors now have better instructions for collecting and analyzing product samples to confirm label accuracy—especially for allergens and nutrients.
More Oversight of Imported Foods
The FDA will apply the same labeling rules to imported products as it does to U.S.-made items. OU Kosher’s global network already helps support compliance in international markets.
What This Means for OU Kosher-Certified Companies
For most companies already certified by OU Kosher, these updates likely confirm existing best practices rather than require major changes. Many kosher-certified plants already follow systems that include:
- Allergen tracking for dairy, meat, sesame, nuts, and more
- Detailed ingredient records for audits
- Label reviews to ensure claims like “non-dairy” or “gluten-free” match production
Still, companies—especially those exporting to the U.S.—should review their labeling to ensure it meets the new FDA requirements.
Transparency, Traceability, and Trust — Shared Goals with OU Kosher Certification
The FDA’s focus on transparency—ensuring labels are accurate, honest, and aligned with public health goals—echoes the core principles of kosher certification. This includes:
- Ingredient traceability
- Allergen control (e.g., sesame in pareve or dairy products)
- Verified documentation across supply chains
OU Kosher’s emphasis on rigorous oversight and third-party verification supports many of the same values the FDA is reinforcing: clarity, compliance, and consumer trust.
Learn more about OU Kosher labeling