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COMPLIANCE POLICY GUIDE (CPG)

CPG Sec 525.400 Hollandaise Sauce - Common or Usual Name March 1995

Final
Issued by:
Guidance Issuing Office
Office of Inspections and Investigations
Human Foods Program

BACKGROUND:

Traditionally hollandaise sauce has been made with butter and other ingredients, but in recent years there has been substantial change in consumer use and acceptance of margarine, *light butter, cream or sour cream* as an alternative or supplementary ingredient for butter. A review of the more commonly used cook books shows that many modern recipes for hollandaise sauce call for use of either butter or margarine *(light butter, cream or sour cream are also acceptable).* Egg yolk is the customary emulsifying ingredient in hollandaise sauce. We have consistently expressed the opinion that starch is not an appropriate ingredient.

POLICY:

In the absence of a standard of identity, "hollandaise sauce" has been considered to be the common or usual name for an emulsion of butter, egg yolk, acidifying ingredients such as lemon juice or vinegar, and seasoning such as salt and pepper.

In view of the fact that *consumers* commonly substitute margarine for butter and the fact that many modern recipes for hollandaise sauce provide for use of either butter or margarine, the Food and Drug Administration will not object to the use of margarine as the fat ingredient of hollandaise sauce with appropriate label declaration. *Neither will FDA object to the use of light butter, cream or sour cream to make a light version.*

Egg yolk is the customary emulsifying ingredient in hollandaise sauce. Starch is not an acceptable ingredient.

Labels for hollandaise sauce must bear a listing of all ingredients in accordance with Section 403(i)(2) of the Act. If margarine, *light butter, cream or sour cream* is used, it should be declared as such in proper order of predominance in the list of ingredients following in parenthesis by a listing of the ingredients in the specific margarine *or other "fat" ingredient* used.

*Material between asterisks is new or revised.*

Issued: 10/1/80
Revised: 3/95


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Submit comments on this guidance document electronically via docket ID: FDA-2013-S-0610 - Specific Electronic Submissions Intended For FDA's Dockets Management Staff (i.e., Citizen Petitions, Draft Proposed Guidance Documents, Variances, and other administrative record submissions)

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