The Agency has considered the labeling of multi-ingredient products used as seasoning. The labeling of two of these products is discussed to provide guidance on the status and labeling. One was a "Pizza Seasoning" containing principally salt, a dried cheese preparation, dextrose and paprika and smaller amounts of tomato powder, onion powder, garlic powder, ground oregano, butylated hydroxyanixole, citric acid, propylene glycol, propyl gallate and oleoresin sweet basil. The cheese preparation contained dehydrated cheddar cheese with added sodium phosphate, salt, lactic acid and certified color. The other product was a "Barbecue Seasoning" containing principally salt, dextrose, sugar, hydrolyzed yeast and lesser amounts of paprika, monosodium glutamate, onion powder, ground cumin, tricalcium phosphate, oleoresin celery and a "smoke" flavor. The "smoke" flavor contained oil of coriander, oil of juniper, isoeugenol, isolates from wood distillates and propylene glycol. Our comments were in part as follows:
Section 403(i)(2) requires naming of individual spices, flavorings or coloring ingredients only in case of articles sold as such. These two articles do contain spices and flavorings but they are not either spices or flavorings sold as such. They belong in a broader category of foods, which for want of a better term might be called "seasonings." There are many substances whose effect on the taste of food is an important consideration in their use, which are neither "spices" or "flavorings" and which we have consistently refused to sanction being declared as "spices" or "flavorings" when used as ingredients. Examples are the dextrose, tomato powder, onion powder, garlic powder, citric acid, salt, cane sugar, hydrolyzed yeast, monosodium glutamate, and tricalcium phosphate in these products. True spices and flavorings comprise a relatively small percentage by weight of these two products. Since the products are not spices or flavorings sold as such the collective term "spices" can be used to declare the spice ingredients (i.e., oleoresins of sweet basil, celery, etc. and the spice oils, and isoeugenol). The nonspice and nonflavoring ingredients are declared by their common or usual names. Wood distillates (pyroligneous acid) should be declared as "artificial flavor" or "artificial smoke flavor" in accordance with 21 CFR 101.22(h)(6).