Customer formulas and specs, rebuilt as your plant's spec, label check and allergen record.

New business arrives as a stack of the customer's documents: a formula by weight or by share of the batch, ingredient specs and approved suppliers, a finished product spec with its own limits, packaging specs, and label copy or artwork. Your team turns that stack into your finished product spec, a batch formula for your kettle or mixer, a check of the label against what will really be in the package, and an entry in your allergen records for the line it will run on. Questions go back to the brand until every gap is closed.

For the test, AI reads copies of that stack for items your team already finished and drafts the plant spec, a label review list and an allergen record for each one, every line pointing to the page of the customer's document it came from. Whatever the documents leave open becomes a question for your reviewer, never a guess. Nothing goes to the customer, and nothing is written to your files.

The ingredient list has to follow the formula. FDA's labeling rule lists ingredients by common or usual name in descending order of predominance by weight. Minor ingredients may be grouped at the end only behind a quantifying phrase, and none of them may exceed the threshold that phrase states. An ingredient made of two or more ingredients is declared with its own components in parentheses, or by folding every component into the main list and dropping the ingredient's name. So the draft lays the brand's label copy over the formula: an order that doesn't follow the weights, a component missing from a parenthesis, or a minor ingredient above its stated threshold becomes a line on the review list. Whether the copy is right stays with the brand and your QA.

The label names the brand, and has to say how it is connected. When a food isn't made by the company whose name is on the label, FDA's rule qualifies that name with a phrase such as "Manufactured for" or "Distributed by", followed by the place of business down to the ZIP code. A label carried over from the brand's previous maker, or one reading "Manufactured by" above the brand's name, goes on the list. So does every claim. Costco's published supplier addendum, for one, asks that claims such as gluten free or non-GMO be validated through testing, certifications or audits, so the draft names the certificate or test report behind each claim in the copy, or leaves a blank where none was sent.

Allergens come from every ingredient, down to the carrier. The draft reads each ingredient spec in the packet for the major food allergens, including those hiding in a seasoning blend or a flavor carrier. FDA's allergen guidance of January 2025 moved the edges: coconut and kola nut are no longer treated as tree nuts for labeling, while milk from goats or sheep counts as milk and is declared by its source, as in "Contains goat milk", and eggs from ducks or quail count as eggs. The law also leaves highly refined oils out of the definition. A declaration sits either in parentheses in the ingredient list or in a "Contains" statement immediately after or next to it. The draft records which ingredient brings each allergen and where the label declares it, and leaves the call to QA.

Your allergen record covers the line, not only the item. FDA's preventive controls rule counts both protection from allergen cross-contact, in storage, handling and use, and correct labeling of the finished food as allergen controls. A new item that brings an allergen onto a line that has never run it changes your schedule and your changeover cleaning, even when the customer's spec says nothing about it. The draft lists the lines the item could run on and the allergens each line already handles, for whoever owns your allergen program. The approved label review becomes the control your line checks against: Costco's addendum asks for labels to be verified against a control on receipt, on each batch of labels, at every changeover and on each lot before shipment.

Some items need a filing, and your reviewer watches the rest. A commercial processor of acidified foods, which FDA's rule describes as low-acid foods with acid added, a water activity above 0.85 and a finished equilibrium pH of 4.6 or below, files each product's scheduled process on Form FDA 2541e, per container size, before packing a new product. The draft marks any item whose spec values could put it in that class, for your process authority to decide, and never files anything. Your reviewer, usually the QA manager or the R&D lead who onboards new items, checks that the customer's limits reached your spec without a changed number, that every label and formula disagreement was caught, that each allergen was traced to its ingredient, and that anything the packet doesn't answer, such as an unnamed supplier or a missing test method, was left open.

Once your reviewer agrees, new packets go through the same drafting for about 30 days, as brands send them.

Each draft stops with your QA or R&D lead, who approves the spec, signs off the label review and updates the allergen record. Questions for the brand go out from your team, in your words.

The side-by-side comparison keeps running on live items, and nothing else starts before the month is over.