See Sec. 585.725 (for CPG 7114.22) - "Pumpkin" is an acceptable designation for labeling articles made from certain varieties of squash.
Packers of canned pumpkin that use pumpkin and/or squash in their "canned pumpkin" may further process the seeds obtained therefrom for food use, or in some cases may sell the seeds to another processor. This practice would naturally lead to our being asked, as we were recently, whether squash seeds, when offered as food, may be labeled and sold as "pumpkin seeds." Horticulturists in the U. S. Department of Agriculture advise us that horticulturally, the difference between the seeds of squash (Cucurbita maxima) and pumpkin (Cucurbita pepo) is slight - there is no difference in the outward appearance - and any other difference is detectable only by an expert.
The U. S. Dispensatory, 25th Edition, states, "Much confusion exists in the usage of the terms 'pumpkin' and 'squash,' these terms having been applied almost indiscriminately to varieties of several species of Cucurbita." It also points out that the British Pharmacopeia of 1914, recognized as "pumpkin seeds," the species Cucurbita maxima which is usually considered as squash in this country.
The designation of "pumpkin seed" will not be considered misleading when used in the labeling of (1) squash seeds which are practically indistinguishable from pumpkin seeds, or (2) mixtures of such squash seeds with seeds of the pie or field pumpkin.
Reissued: 8/23/73, 10/1/80, 12/8/88