This guide covers FDA registration for spices and seasonings, the GRAS spice list and collective “spices” ingredient declaration, Salmonella controls and Import Alert 99-23, lead and heavy metal contamination, food fraud hazards, the 1/4 teaspoon RACC, sesame allergen (FASTER Act 2023), and irradiation labeling requirements.
The Nutrition Facts panel for most ground spices must use 1/4 teaspoon (approximately 0.6g) as the serving size basis. Many imported spice products use European-style per-100g comparison formats or other home country serving sizes that do not satisfy FDA’s RACC framework. Using the wrong RACC serving size is misbranding under 21 U.S.C. § 343.
Sesame is the 9th major U.S. allergen since January 1, 2023 (FASTER Act). Spice blends and seasoning mixes containing sesame seeds, sesame oil, or any sesame-derived ingredient must declare sesame as an allergen: “Contains: Sesame” or bold “sesame” in the ingredient list. Many spice blend manufacturers have not yet updated U.S. labels. Note: Mustard and celery are NOT U.S. major allergens despite being EU allergens.
Irradiation is an FDA-approved Salmonella treatment for spices under 21 CFR Part 179. If a spice has been irradiated, the label must carry the radura symbol (international irradiation symbol) AND the statement “treated with radiation” or “treated by irradiation.” An irradiated spice without this disclosure is misbranded. Many spice importers use irradiation as their Salmonella control but omit the required label disclosure.
Under 21 CFR 101.22(a)(2), onion, garlic, and celery are excluded from the FDA definition of “spice.” They must be declared individually by name in the ingredient list — cannot be lumped under “spices.” A seasoning blend containing garlic powder and cumin must list “garlic powder” individually while cumin can be included in “spices.” This is a common labeling violation for spice blends.
FDA Registration Assistance reviews spice and seasoning labels for: GRAS spice collective declaration accuracy; garlic, onion, celery individual declaration; 1/4 teaspoon RACC serving size; sesame allergen (FASTER Act January 2023); irradiation disclosure; paprika/turmeric color additive declaration where applicable; and 2020 Nutrition Facts format.
U.S. spice importers must maintain FSVP for each foreign supplier. FDA Registration Assistance develops FSVP programs addressing all four spice-specific hazards: Salmonella (pathogen reduction verification), lead and heavy metals (periodic testing from higher-risk origins), economically motivated adulteration (species identity and fraud testing), and aflatoxin (for susceptible categories).
FDA Registration Assistance provides complete FDA compliance for spice and seasoning manufacturers and importers — Food Facility Registration with correct activity codes, U.S. Agent services, label compliance review, FSVP programs covering all spice-specific hazards, and Biennial Renewal management. Complete service: $858. FDA charges $0. DUNS fees separate. 1,000+ clients. 135+ countries. 15+ years of FDA regulatory experience.
Contact us at info@fdaregistrationassistance.com or call +1 (928) 275-8333.
Yes. All facilities must register under 21 U.S.C. § 350d and 21 CFR Part 1 Subpart H. Foreign manufacturers must designate a U.S. Agent. Spices are one of FDA’s highest-scrutiny import categories due to Salmonella contamination, heavy metals, and food fraud. Complete service: $858. FDA charges $0. DUNS fees separate.
Under 21 CFR Part 182.10: allspice, anise, basil, bay leaves, caraway seed, cardamom, celery seed, chervil, cinnamon, cloves, coriander, cumin, dill, fennel, fenugreek, ginger, horseradish, mace, marjoram, mustard flour, nutmeg, oregano, paprika, parsley, pepper (black, white, red), rosemary, saffron, sage, savory, star anise, tarragon, thyme, turmeric, and vanilla. Spices from this list may be collectively declared as “spices” in ingredient lists.
Yes — for spices from the GRAS list (21 CFR Part 182.10). Under 21 CFR 101.22(h), these may be collectively listed as “spice” or “spices” — trade secret protection for proprietary blends. Exceptions that must be declared individually: onion, garlic, celery (excluded from FDA’s spice definition); paprika and turmeric when used primarily for coloring.
Under 21 CFR 101.22(a)(2): any aromatic vegetable substance in whole, broken, or ground form (except substances traditionally regarded as foods like onion, garlic, celery) whose significant function is seasoning rather than nutrition, that is true to name, and from which no volatile oil has been removed. Onion, garlic, and celery are explicitly excluded and must be declared individually.
Yes — it is the primary biological hazard. FDA’s survey found ~7% of imported spices contaminated with Salmonella. High-risk categories: black and red pepper, cumin, oregano, coriander, paprika from South Asia and Central America. FSMA hazard analysis must address Salmonella as requiring validated preventive controls (heat treatment, irradiation). FSVP supplier verification must confirm the foreign supplier’s pathogen reduction process.
Import Alert 99-23 covers pesticides, chemicals, and filth in food including spices. Spice products from foreign manufacturers found to contain Salmonella, excessive pesticide residues, or other contaminants are subject to Detention Without Physical Examination (DWPE) — automatic detention of every shipment from that facility. Removal requires demonstrating the underlying compliance issue has been corrected.
Yes. South Asian spices — particularly turmeric, cumin, coriander, paprika — have shown elevated lead levels in FDA sampling. Turmeric is at specific risk for intentional lead chromate adulteration — a yellow pigment that has caused actual lead poisoning outbreaks. FSVP must address lead as a chemical hazard with periodic product testing from higher-risk origins.
Intentional fraudulent addition for economic gain. Spices are a top FDA food fraud category. Common: turmeric adulterated with lead chromate; paprika and chili powder adulterated with Sudan Red dyes (prohibited carcinogenic dyes) or fillers; saffron adulterated with synthetic colors; pepper adulterated with papaya seeds. FSVP hazard analysis must address EMA for each high-risk spice type.
Under 21 CFR Part 117: written food safety plan; hazard analysis addressing Salmonella (biological), lead and heavy metals + aflatoxin + EMA (chemical), and physical hazards (foreign materials); preventive controls including validated Salmonella treatment and supplier controls; monitoring; corrective actions; verification; and a PCQI overseeing the food safety system.
Paprika, chili powder, and nutmeg are susceptible to aflatoxin from Aspergillus mold under high humidity storage. FDA action level: 20 ppb total aflatoxins for human food. Spice importers sourcing these categories should include periodic aflatoxin testing as a supplier verification activity.
Under 21 CFR Part 101: statement of identity in English; net quantity; Nutrition Facts in 2020 FDA format with the RACC (1/4 teaspoon for most ground spices); complete ingredient list (GRAS spices collectively as “spices”; garlic, onion, celery individually); allergen declarations including sesame (FASTER Act January 2023); irradiation disclosure if applicable; and manufacturer/distributor name and U.S. address.
Under 21 CFR Part 101.12: 1/4 teaspoon (approximately 0.6g) for most ground spices. Many imported spice products use European per-100g comparison formats that do not satisfy FDA’s RACC requirement. Non-compliant serving size = misbranding under 21 U.S.C. § 343.
Yes. Sesame is the 9th major U.S. allergen since January 1, 2023 (FASTER Act). Spice blends containing sesame seeds, sesame oil, tahini, or any sesame-derived ingredient must declare sesame: “Contains: Sesame” or bold “sesame” in the ingredient list. Note: mustard and celery are NOT U.S. major allergens despite being EU allergens.
Yes. Irradiation is an FDA-approved Salmonella treatment under 21 CFR Part 179. If irradiated, the label must carry the radura symbol AND the statement “treated with radiation” or “treated by irradiation.” An irradiated spice without this disclosure is misbranded. Many importers use irradiation as their Salmonella control but omit the required label disclosure.
Under 21 CFR Part 1 Subpart L: FSVP for each foreign supplier. Hazard analysis must address: Salmonella (verification of validated pathogen reduction process); lead and heavy metals (periodic testing from higher-risk origins); EMA including lead chromate in turmeric and Sudan Red in paprika; aflatoxin (for susceptible categories); and pesticide residues.
Salmonella contamination; facility on Import Alert 99-23; FDA registration expired; pesticide residues exceeding tolerances; lead or heavy metal contamination (South Asian spices); aflatoxin in paprika or chili; economically motivated adulteration (Sudan Red, lead chromate); missing irradiation disclosure; insect/rodent filth; labeling violations including missing Nutrition Facts or non-compliant RACC serving size.
Yes. Must register and designate a U.S. Agent with a physical U.S. address. FDA Registration Assistance provides U.S. Agent services for foreign spice manufacturers.
FDA Registration Assistance charges $858 — U.S. Agent designation for foreign manufacturers, activity code selection, food product category selection, registration submission through FURLS, and Biennial Renewal management. FDA charges $0. DUNS fees are separate.
When used primarily for flavor: may be included in the collective “spices” declaration (both are on the GRAS list). When used primarily for coloring: should be declared as a color additive (“paprika color” or “turmeric” as a color) — the primary function determines the declaration. Under 21 CFR 101.22(a)(2), a spice is a substance whose significant function is seasoning rather than coloring.
No. Under 21 CFR 101.22(a)(2), onion, garlic, and celery are explicitly excluded from the FDA spice definition. When used in a spice blend, they must be declared individually by name — garlic powder, onion powder, celery seed. Cannot be included under the collective “spices” declaration.
FDA Food Facility Registration renews every two years — October 1 through December 31 of even-numbered years. A lapsed registration triggers OASIS detention of every subsequent shipment. FDA Registration Assistance manages Biennial Renewal automatically.
Imported spices must comply with EPA pesticide tolerances for the specific pesticide/spice combination. Import Alert 99-23 covers pesticide residue violations. Some pesticides used in foreign countries are not registered for U.S. spice crops — residues without an applicable U.S. tolerance result in automatic import refusal. FSVP should include periodic residue testing for higher-risk origins.
Missing sesame allergen declaration (FASTER Act, January 2023); including garlic, onion, or celery under “spices” (must be declared individually); non-compliant serving size (per-100g format instead of 1/4 teaspoon RACC); missing irradiation disclosure for irradiated spices; missing Nutrition Facts panel; no FDA facility registration; no FSVP for imported spice components.
Complete FDA compliance: Food Facility Registration with correct activity codes; U.S. Agent for foreign manufacturers; label compliance review (GRAS collective declaration, sesame allergen, irradiation disclosure, 1/4 tsp RACC); FSVP programs covering all spice-specific hazards; Biennial Renewal. $858 service. FDA charges $0. 1,000+ clients. 135+ countries.
Contact FDA Registration Assistance at info@fdaregistrationassistance.com or call +1 (928) 275-8333. Provide your facility name and address, spice and seasoning products you manufacture, whether domestic or foreign, and any existing FDA registration information. Complete service: $858. FDA charges $0. DUNS fees separate.