When FDA issued the proposed regulation for front-of-pack nutrition labeling (the Nutrition Info Box), it issued a handout with an illustrative example. The product is a frozen veggie bowl that includes “fresh” basil. However, does this violate 21 CFR 101.95 where FDA defines “fresh” and “fresh frozen”? Thoughts?

Perhaps ironically, FDA issued the “fresh” reg as part of the process of implementing the Nutrition Labeling and Education Act, which originally mandated nutrition labeling for all food products.