Inspections, Compliance, Enforcement, and Criminal Investigations
CPG Sec. 505.200 "Butter" Featured in Product Name
There have been inquiries as to what is required to feature the word "butter" in the labeling of a product as "Butter Cookies," "Butter Shortbread," etc.
The Food and Drug Administration will consider a name "Butter ____________ " or the use of the word butter in conjunction with the name as false and misleading unless all of the shortening ingredient is butter. If the product contains both butter and shortening but a sufficient amount of butter to give a characteristic butter flavor to the product, an appropriate name would be "butter flavored ____________." However, if the product contains any artificial butter flavor it would have to be labeled in compliance with 21 CFR 101.22(i)(2).