lo Proposed Label

For those of us in printing, especially package printing, understanding and keeping up with government regulations can be a thorn in the side. Now don't roll your eyes or start huffing at the thought just yet. If we choose to look at the glass as half full, we can embrace these changes as "opportunities"! On the one hand, a steady feed of changes or updates to regulations for things like food and drug packaging means job security and another "opportunity" to make a little money for printers and prepress shops. For the CPCs (Consumer Product Companies), it opens the door (another way to say "opportunity") for consideration of other changes as well, perhaps a chance to give the graphics a little face lift. Right! ...But I am guessing these are not your initial sentiments when you are generating a barcode or hear about a new set of requirements for nutritional panels. Frustration, confusion and fear, mixed with a little irritation are probably more common reactions.

What makes us quake a little? I think it is the uncertainty of a system filled with hard to decern rules and yet the potential to face stiff penalties when not followed correctly. Some specifications are general while others are very specific and there are rules that apply to all aspects of the label or package to include font sizes, product identification, manufacturer information, quanitity information, where art (or nonessential material) is NOT allowed, food addititves and ingredients, food allergens, nutritional information, barcodes and warning statements. Now the regulations I am discussing within this article are more specifically related to the graphics, for things like font specifications, barcodes, ingredients panels and nutritional panels.

Food and drug labeling requirements come from and are governed by a variety of sources, most noteably the FDA, USDA, EPA and GS1. While the CPCs are, in general, the most well versed and equipped to ensure the product meets these labeling requirements, it is important that each member in the supply chain does their part to help ensure compliance before the product ends up on the shelf. I expect most CPCs are armed with a team of individuals that keep up with these regulatory sources and determine when and how a label or package is to be updated. As a prepress provider though, you can help establish your relevance as the CPC's supplier if you have check points built into your process to ensure you are following the latest rules and employing the current formats.

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Pending Changes for the Nutritional Panel

Take for example the FDA's notification earlier this year about changes to the nutritional panel. A little history on the matter may be helpful. In the early 1860's our government initiated the Bureau of Chemistry and the Department of Agriculture which eventually became what we know today as the Food and Drug Administration (FDA, effective 1930). However, it wasn't until 1990 that the Nutrition Labeling and Education Act (NLEA) was passed, at which point the FDA really began to standardize health claims to include the ingredient information, serving sizes and terminology indicating a product as "low fat" or similarly. By 1993 the first version of a nutritional table with per serving information was finalized and has for the most part remained unchanged, except for the addition of trans fat information in 2006. Come 2015, the FDA will release the new and improved nutritional table format aimed to make it easier to read and understand (see image 1 ). Parts of the label, such as calories will be more pronounced. You can also expect to see some new information, like added sugars, while other information will be removed. Serving sizes will even be changing to more accurately reflect a true serving size based on today's standards. All in an effort to make the label and information within it a more valuable tool for consumers to coorelate to health risks like obesity, high blood pressure and cardiovascular diseases.

Once finalized the industry will have two years (from the effective date) to make sure labels and packaging are in compliance. While CPC's have most likely already engaged their teams to start researching these changes for their product lines, it will certainly take time to update all product labels to conform.

If you are interested in more details click this link for FDA Proposed Nutrition Fact Changes. The three specific areas addressed by these changes include:

  • Greater Understanding of Nutrition Science
  • Updated Serving Size Requirements and New Labeling Requirements for Certain Package Sizes
  • Refreshed Design
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Solutions to Help Ensure Compliance

The good news is that there are simple software solutions for prepress providers to help ensure a new product label is in compliance with these regulations as well as update legacy art by updating the parameters or affected elements, provided software is kept up-to-date. At this point I am going to address the first level of defense and in part two of the article I will discuss powerful dynamic solutions.

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The first step is to start by preflighting the file, which quickly scans the job identifing things like font size issues (see image 2 ). Ideally you need a tool that doesn't simply provide a list of violations, but actually highlights each error in the artwork and allows the operator to zoom into desired areas so the user can better evaluate and correct within Illustrator® (see image 3 ). Adobe Illustrator® is the primary design application used for package and label printing. Of course a preflighting tool shouldn't look at just text and font sizes, it inspects all art elements and highlights violations based on a given set of print parameters.

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Common Preflighting Check Points:

  • Fonts (min point size of positive / negative / multi color / serif / sans serif styles)
  • Line weights (min point size of positive / negative / multi color styles)
  • Min / Max Dot
  • Small objects
  • Ink coverage infringements
  • Image resolutions
  • Inks: max process / max spot
  • Etc.

However, an even bigger aide in ensuring regulatory compliance comes in using dynamic content to build things like barcodes and nutritional panels. This can be accomplished using a suite of tools with intelligence built-in to understand requirements and provide access to approved formats for that element. The second part of this article will dive into this topic a little deeper addressing barcodes, nutritional panels and other regulated art elements.

Are you ready for more fun with regulatory compliance? ...Actually this part is pretty cool and a little more fun. In the first part of this discussion I talked about where labeling regulations are derived, the types of package/labeling elements that are regulated and how prepress providers can use software to aide in meeting many government labeling requirements. Remember, my focus in this article is regulations related more specifically to the graphics, for things like font specifications, barcodes, ingredients panels and nutritional panels. As an example, I mentioned an upcoming Nutritional Panel change that will be pretty significant. If you didn't take the time to check out the link provided or did not see the first part of this article, you should click this link to learn more about the FDA Proposed Nutrition Fact Changes. I also talked about the first layer of defense everyone should use when opening an art file – preflighting. Some solutions are very intuitive and act as a guide allowing the user to move through the file and correct elements as needed. But preflight is really only the tip of the iceberg when it comes to most of graphic related regulations. At this point I will discuss using dynamic content to build things like intelligent barcodes and nutritional panels.

How Smart is your Barcode Builder?

Barcode generating programs have been around forever and are essential to successfully creating a barcode with the correct bars and spaces, size, magnification, bar width reduction and height. There are a variety of applications you can purchase and use to build a barcode, which can then be placed into Illustrator®. Since you are creating a [raster-based] image file a change to that barcode requires going back to the barcode application to generate a new code. The bad barcode must then be deleted from the Illustrator® file and the corrected code placed and repositioned where needed within the design. Though a bit tedious, this is a familiar process to most any prepress artist.

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One well-known software developer is Esko. They have a barcode solution that is unique for three main reasons. First, it is a tool you can use within Illustrator®. Second, and what really sets it apart, is that the barcode generated is not an image file, but rather vector art that is automatically placed in a separate non-destructive art layer. Since it is vector art it is easy to change things, like the barcode's color for example, similar to how other vector art is manipulated using native Illustrator® tools. But this is not really necessary due to the third feature, the barcode panel, which allows the user to dynamically create or update a barcode. Using this panel, the operator can conveniently edit the barcode's color, size, magnification, number, etc.. They can even customize the font and placement of the human readable characters (see image 4 ). Let me reiterate, all of this is accomplished without ever leaving Illustrator® and is built on a non-destructive art layer. Every change made in this panel is immediately reflected by the barcode within the art file.

Pretty nice, but what would be even better is for the prepress artist to not have to enter the UPC code at all. What if it could be dynmically linked to a code provided by the CPC? With Esko's suite of tools, this too is possible, by creating a vector barcode as a placeholder using their dynamic tools. This can then be linked to a customer provided XML file with the correct code information, which usually comes from the brand manager (see image 5 ). As you can see, each part of this dynamic tool set allows the artist flexibility and yet builds in layers of protection to minimize errors and maintain regulatory compliance.

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Consumed With What We Eat

So I have already mentioned, a couple times now, about the upcoming nutritional panel changes. This marks the first major change since 1993, if you don't count the 2006 change to add trans fat to the nutrients. These changes are under review, but expected to be finalized by 2015, at which point the industry will have two years (from the effective date) to make sure labels and packaging are in compliance. As CPC's start to define changes for their product lines, we can certainly expect a to see a gradual escalation in urgency to adopt the new regulations and ensure all product labels conform.

For those of us in packaging who actually generate these tables the thought of changing all the nutritional panels for all the products we manage may be a daunting and tedious task to face. These changes will involve the shifting, adding, removing and rekeying of a lot of information, not to mention potentially having to adjust positioning of text and other art elements that surround the nutrition facts. If you have been building these tables manually, this would be a good time to consider investing in a solution that will allow you to dynamically build and populate this information. Many of you may already be using a cloud-based solution or other software specfically developed for building nutritional panels. Once again, Esko offers a unique tool for easily building and changing nutritional panels in a non-destructive art layer. This dynamic tool is another Illustrator® plug-in and includes access to all types of panel formats for which you can manually type in the desired values or link the table with XML data to automatically populate the information. Since all the tools reside within Illustrator® the operator can effortlessly move between tools and does not need to open other applications or go through the process of placing images and then respositioning the art.

The example images (see image 6 ) show the U.S. Linear nutritional panel format and a second customized version where the cholesterol measurment field has been removed from the panel. A third option shows the panel converted to the U.S. Standard Full format. While the nutrition data stays the same you can see the style in which it is displayed is very different. Similar to Esko's barcode tool, the changes are made via the a panel and the art immediately reflects the changes so the artist never has to leave Illustrator®, thus making the art itself dynamic.

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My Art is Smarter then Your Art

I can sense you really do want to consider governmental regulations and the implementation of all these standards as "opportunities", but to do that, you need to be able to manage your frustration, confusion and fear so that it is as simplified a process as it can be. While the brand colors and images are definitely important, as this is what grabs the consumer's attention from the shelf, errors with simple line art (like barcodes, ingredients, nutritional info, etc.) can sting way more then any color shift. There are plenty of resources you can research and purchase or use online, but removing as many touch points as possible is the ultimate key to success. This is why dynamic content makes so much sense. The ability to draw XML data from other systems and then link the XML data to placeholders within your file helps to eliminate additional touch points. That is one less thing the operator has to key-in and that means one more chance to make a mistake is averted.

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I have already touched on this briefly with barcodes, but any art can be made intelligent and dynamic. By tagging the art element as dynamic, it becomes a placeholder (see image 7 ). This placeholder then acts as a bridge linking it with intelligent content (XML data created by a CPC's content management system) to the file. In essence the design is made "smart", triggered by dynamically linked art elements. A placeholder barcode (made of all zeros) becomes a live barcode. A nutritional panel or ingredients list is populated with content. An image element is replaced with the correct or updated art. Multiple versions of a product are dynamic adapted (see image 8 ).

But wait! It gets even better! The next stepping stone is to connect this to a web-portal to make this a cloud-based solution. Combining a web-portal with dynamic art, the operator can invite and collaborate directly with the CPC and others. This especially makes good sense when it comes to governmentally regulated art for things like barcodes, nutritional panels and ingredients list. Lawyers, brand managers, marketing groups, these people are the ones in the know and why not try to streamline this process and allow them direct access to help mange specific content.

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Wrapping Things Up

Here are a few key things to consider when selecting your ideal solution:

  • Tools reside within Adobe Illustrator®
  • Art is built on a non-destructive art layer
  • Content is locked so it is protected from accidental, non-deliberate changes
  • Changes are instantly mirrored within the art file via dynamic links
  • Elements can be linked to XML data provided by the brand owner/manager
  • A window can be opened allowing the prepress supplier to link other key individuals and decision makers as the package/label is being created

These things will all go a long way to improving efficiencies. Think of the time an operator can save by not having to jump back and forth between applications, removing the old and then adding and repositioning new art. Hopefully these solutions not only provide a little piece of mind, but also make the prepress supplier an even more valuable asset to the CPC. Regulations are going to continue to change as these groups (like the FDA, USDA, GS1, EPA, etc) work to improve and adapt packaging to our evolving understanding of buisness needs, consumer health and the products being packaged. Most software developers are doing their part to stay in the loop and keep their solutions relevant. What helps protect you as the prepress supplier is having solutions and tools that make it simple and keeping those systems current so you have access to new formats and requirements based on the latest and greatest regulations.

About the Author: Catherine Haynes is a member of the Technical Solutions Group for All Printing Resources. She has more than 18 years of experience in the printing industry and has been a certified G7 Expert for more than six years. At APR she assists sales technicians as a technical representative for various customer projects related to training, characterizations, prepress and pressroom assessments, color management, digital workflows, platemaking and implementation or expansion of in house prepress capabilities.

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