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  • the designations of origin (farm, river, lake) for catfish, which provide potentially useful information to consumers, should be considered by FDA as a candidate for an advisory opinion or incorporated into Federal regulations.

  • because FDA policies for labeling surimi-based products appear to provide adequate regulation, State requirements are candidates for preemption.

Miscellaneous State Food Labeling Requirements

The foods listed below are subject to State labeling requirements. Each represents a unique food or a food of special commercial interest and is subject to regulation by only one or two States. They have been grouped in this section for convenience in presenting the Committee's conclusions and recommendations.

Maple Syrup

Two States (N.Y. Agric. & Mkts. Law §203 and §204; Vt. Stat. Ann. Title 6, §492, §493) cited varying requirements related to standards of identity, quality, grading, and common name of origin for maple syrup and related products. In particular, Vermont argued that its standard of identity and grading system for maple syrup and related products were superior to FDA's standard of identity and USDA's grading standards. Both of these issues fall outside of the charge to the Committee.

Conclusions The Committee concludes that the State maple syrup requirements reviewed are either standards of identity and preempted under NLEA Section 6, or grade standards and not subject to NLEA preemption; and therefore, are not subject to study.

Olive and Vegetable Oils

California law requires that products presented as olive oil may be only the oil of the olive tree, in the absence of added color or flavor. The oil may be blended with other oils only if it is clearly labeled (Cal. Health & Safety Code §28475 to §28478, §28480 to §28482, §28454 to §28486). Rhode Island has a similar law that requires identification of blends containing olive oil (R.I. Gen. Laws §21-21-1, §21-21-2, §21-21-6). New York law further



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