Do you know your labeling requirements?

In the past month or so, I’ve come across a number of people discussing labeling requirements, mostly for farm produced items. In Virginia, I think we are fortunate that there are many exemptions for the small farm producer. If you have purchased any of my products, you will know that I label everything and I do follow the regulations. Something you might not know or think about is how this adds cost to our final product. Mostly it’s time, but labels aren’t cheap. New egg cartons, if I can get them on sale with free shipping, cost 35 cents each. If you use a printer, you know how expensive ink is. Good software to create eye pleasing fonts and graphics is also costly. So what does this mean to you as a consumer? As a producer? For me it means that I can’t compete with the person who sells their eggs at the farmers market for $2 per dozen in used cartons. I sell mine for $2.50 per dozen with the request to return my carton. This is not that important to me now because we don’t sell our eggs at the market. We sell them all to friends and co-workers, but I would like to be able to compete if I ever have enough to do so.

While I’m on the subject, please price your items appropriately when you are selling them. I know lots of people say they are not trying to make money, just getting rid of their excess. When you devalue your product, it lowers the value for everyone not just yourself. If you are not trying to recoup your feed cost or put money into your family budget, please think of others that are. I was reading the regulations of a farmers market here in Virginia that actually requires their vendors to maintain a price structure. “No vendor of produce may sell products at a price 10% below the current market value for retail farmers’ markets as reported by the VA Dept. of Agriculture”. Wow, good for them! I wish all farmers markets would adopt this practice. It’s good for the vendors and consumers alike. And if you are not trying to recoup your feed cost, why aren’t you? I would love to know why. Please leave a comment below so we can discuss this important issue.

Anyway, off my soap box about pricing and back to the one about labeling. What does Virginia law state about selling eggs as a small producer?

“EGGS

The marketing of eggs in this state falls under the Virginia Egg Law. Producers selling a total of 150 dozen eggs or less per week produced by their own hens or eggs purchased from other producers not to exceed 60 dozen per week are exempt from this law provided all of the eggs are of edible quality. However, shell eggs being offered for sale at the farmers’ market must be clean, held at 45F or less at all times, and labeled with the following:

Safe Handling Instructions: To prevent illness from bacteria: keep eggs refrigerated, cook eggs until yolks are firm, and cook foods containing eggs thoroughly.

Name & Address of Packer

Grade: Eggs should be labeled with a suitable consumer grade (AA, A, or B) or “Ungraded”. Eggs labeled with a consumer grade should meet the corresponding standards for that grade.

Name of Product: The term “fresh eggs” may only be used if the eggs meet the requirements of Grade A quality or better.”

The above quote came from a farmers market pamphlet, but they apply no matter where you sell your eggs. We don’t have our eggs inspected so our label says “ungraded”. We are also careful not to use the phrase “fresh eggs”. We use the term “pasture raised”. My safe handling instructions are tucked into the carton and contains the required information, instructions for washing (we currently don’t wash our eggs, but may in the future) and a fun fact about egg colors.

So really, why is this so important? As a producer, why would you want to sell your product in someone else’s carton? Not only are you not giving them a way to contact you for more, you are giving the original seller free advertising. That’s not good for your business. I want to make sure that my customers have my contact information handy if they have any questions or want to recommend our eggs or any of our products to others. I also see this as a value added addition to our product. My cartons and my labels don’t look like anyone else’s and I think the personal touch is something consumers like when they are buying from a small business. Why would we want to be compared to a large chicken farm? Our chickens free range and even though they are not pets, they get treats and some of them get picked up for beak scritches (yes, that’s a technical term!!) when they want them. It’s a pleasure to go to the barn and see chickens squawking and running to me when they see me walking into the pasture. They are happy to see me and I return their sentiment. They’ve made my life happier!

Here is the regulation for meat poultry:

Special Exemption for Poultry—Anyone who slaughters and processes less than 1,000 poultry in a calendar year is exempt from the Poultry Products Inspection Act. These poultry must have been raised on his/her own farm and sold within the Commonwealth of Virginia. Up to 20,000 birds may be slaughtered/processed annually with periodic inspection. {9CFR 381.10 (b) and (c)}

And here is the exemption for food items:

http://leg1.state.va.us/cgi-bin/legp504.exe?081+ful+SB272ER

3. Private homes where the resident processes and prepares candies, jams, and jellies not considered to be low-acid or acidified low-acid food products and baked goods that do not require time or temperature control after preparation if such products are: (i) sold to an individual for his own consumption and not for resale; (ii) sold at the private home or at farmers markets; and (iii) labeled “NOT FOR RESALE—PROCESSED AND PREPARED WITHOUT STATE INSPECTION.” Nothing in this subdivision shall create or diminish the authority of the Commissioner under § 3.1-399;

Now you know what they are and where to find them. Would like to know your thoughts on the subject. Please leave a comment below and I’ll try to get an answer for you. Happy farming everyone!

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