Vanlaw Food Products, Inc – FDA Warning Letter, Mar 28, 2023

The FDA issued a Warning Letter to Mr. Llorente on January 5, 2023, regarding misbranded Whole Foods 365 Organic Creamy Caesar Dressing. The product was misbranded under section 403(w) of the Federal Food, Drug, and Cosmetic Act because its label failed to declare major food allergens, wheat and soy. This also constitutes a violation of the Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food regulation (21 CFR Part 117), specifically 21 CFR 117.135(a)(1) and (c)(2), for not implementing adequate preventive controls for undeclared allergens.

The firm initiated recalls on August 25, 2022, and September 19, 2022, for lots manufactured on July 6, 2022, and August 2, 2022, respectively, due to mislabeling with 365 Organic Classic Ranch Dressing and Dip back panels. The firm admitted that relabeling was not monitored, not verified, and not considered part of the workflow, and that a temporary employee may have inadvertently placed mislabeled bottles on the line. A previous recall for the same product occurred on April 4, 2022, due to an incorrect Whole Foods Market Organic Blue Cheese back panel, also failing to declare wheat and soy.