I have been doing some interesting light reading of late—the USDA’s Food Standards and Labeling Policy Book. I ran across some “new to me” information that I found exceedingly surprising and a bit disconcerting. I recently confirmed the information via email with the USDA. The single word “starch” in the ingredients list of a food product regulated by the USDA can mean either corn starch or wheat starch.
It has been believed for years that the single word “starch” on any food label in the US means “corn starch.” This belief was based on the FDA’s Compliance Policy Guide for starch which states,
For purposes of labeling in accordance with Section 403(i) of the Federal Food, Drug, and Cosmetic Act, and Section 4(a)(1) of the Fair Packaging and Labeling Act, the term “starch” is considered the common or usual name for starch made from corn; alternatively, the name “cornstarch” may be used.
Starches from other sources should be designated by some non-misleading term that indicates the source of such starch, for example, “potato starch,” “wheat starch,” or “tapioca starch.”
While this remains true for FDA-regulated foods it seems it was never true for USDA-regulated foods.
According to email correspondence with USDA they follow the FDA’s Code of Federal Regulations Standards of Identity. BUT in cases where there are no standards of identity (including in the case of starch where only a CPG exists) FSIS can develop their own policy. Unfortunately, guidance is not necessarily the same between FDA and USDA.
The Food Allergen Labeling and Consumer Protection Act (FALCPA) FALCPA amended the Food, Drug, and Cosmetic Act. It requires that packaged foods regulated by the Food and Drug Administration clearly state on the food label when a food or an ingredient in a food is or contains protein from one of eight major allergens, including wheat. FALCPA did not amend the Federal Meat Inspection Act, Poultry Products Inspection Act, or the Egg Products Inspection Act under which the Food Safety and Inspection Service (FSIS) of the USDA regulates meat, poultry, and egg products.
The USDA regulates meat products, poultry products, egg products (meaning any dried, frozen, or liquid eggs, with or without added ingredients), and mixed food products that generally contain more than 3 percent raw meat or 2 percent or more cooked meat or poultry meat.
Currently, under FSIS regulations all ingredients must be listed in the ingredients list by their “common or usual name.” Common or usual names include modified food starch, starch, dextrin, and malt. Unfortunately, common or usual names do not always indicate the source of the ingredient. BUT while the USDA does not have mandatory allergen labeling at this time, the FSIS believes they have widespread voluntary compliance (approximately 80 to 90 percent) with allergen labeling among their manufacturers.
What to do if you see “starch” in the ingredient list of a USDA-regulated food?
Based on my limited perusal of egg products, meat products, and poultry products, it is rare to come across a product listing the single word “starch” in the ingredient list. It is far more common to come across “modified food starch.”
In a previous interview with a Deputy Director of the Labeling and Program Delivery Division of FSIS, the following recommendation was given for other ingredients that might contain wheat protein:
“Modified food starch” and “dextrin” are acceptable ingredient declarations on the labeling of meat, poultry, and egg products. If these ingredients are derived from wheat, the declaration of “wheat” could be highlighted in an allergens type statement that most establishments are voluntarily including on their product labels. If the label does not bear an allergens statement and a consumer is unclear as to the source of the modified food starch or dextrin, they should contact the manufacturer or distributor for clarification. The name and address of the manufacturer or distributor is a required labeling feature on meat, poultry, and egg products.”
If you are concerned, it would seem prudent to follow the same advice for “starch.”
Note: It is far more likely that “modified food starch,” “dextrin,” and “starch” will be derived from corn starch than wheat starch.
For the entire interview, please see
Bottom line: The single word “starch” in the ingredient list of a USDA-regulated food can mean either corn starch or wheat starch. If there is no indication on product packaging that the manufacturer is voluntarily complying with FALCPA-like allergen labeling and you have concerns about this ingredient, contact the manufacturer.