Bryan Cave Digest


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It’s Time to Renew Your Food Facility Registration!

Beginning on October 1, 2014, food facilities required to be registered with the FDA must renew their food facility registrations.  The FDA currently requires registration for all domestic and foreign food facilities that manufacture, process, pack, or hold food for human or animal consumption in the United States.  This food facility registration must be renewed every two years, and the current registration period lasts until December 31, 2014.  FDA has published a number of guidance documents to assist with the food facility registration requirements, including a Q&A document and a Small Business Compliance Guide.  More information on registration procedures can be found on FDA’s website.

Food and Beverage Class Actions Are on the Rise

September 19, 2014


The latest Bryan Cave white paper on advertising class actions indicates an increase in class action filings affecting the food and beverage industry.  The paper, which analyzes class action complaint filings in the first two quarters of 2014, reveals the following:

  • Nearly 50% of the advertising class action complaints during the relevant time period were in the food and beverage (36%) or dietary supplement (12%) industries.  This number jumps to nearly 75% if other industries regulated by the Federal Food, Drug and Cosmetic Act are included. (Cosmetics accounted for 11%, pharmaceuticals for 8%, weight loss and pet care products for 4% each.)
  • Each quarter in 2014 represents a significant increase when compared to the last quarter of 2013.
  • Most of these food and beverage advertising class actions related to food labeling and nutrition content (26%), although “natural” claims still comprise a significant number of filings (18%).

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