The Evolution of Naked Fries Packaging

The Evolution of Naked Fries Packaging

If you only take one thing away from this article: hire a Packaging Compliance Consultant.

Written by Lauren Grazioso, Co-Founder of Naked Fries. Originally published on The Naked Fries Substack.

One of the greatest lessons I learned while building Naked Fries is the amount of rules and regulations there are when it comes to food packaging. AND that there are firms that specifically go after brands for not meeting these regulations.

For example, did you know the common name of your product needs to be on the package? Probably… but did you know that it needs to be no less than half the height of the brand name? Or you can only be a “Low Calorie” food if you have 40 calories per serving? Me neither… Safe to say if my partner didn’t suggest hiring a Package Compliance Consultant, we’d probably have a few lawsuits under our belt.

Let’s get into what those lawsuits could have been for - Starting with the front of the package…

Here were some of the biggest changes we had to make:

  • The common name was missing. We had to add “French Fried Potatoes” to the front of the package, and it has to be at least half the height of the brand name. Did other people know the common name was required??
  • Our net weight needed to be reformatted. It has minimum size requirements (yes, based on the height of a lowercase “o”) and can’t be stretched or compressed beyond certain proportions."
  • The net weight format also matters. It needed to follow the proper format: NET WT 18 OZ (1 LB 2 OZ) 510 g.
  • Nutrition claims can’t overpower the name of the food. Claims about calories, fat, etc. can only be so prominent compared to the statement of identity.
  • Because our fries are enlarged on the front of the bag, we needed to add “Enlarged to show detail.”

There were also a few changes that weren't technically required but made the packaging stronger:

  • “240 Calories per ½ Bag.” We realized this wasn’t all that helpful since people usually compare products by serving or by the entire package.
  • “Stripped of Everything but the Taste.” We loved this line, but it could also be interpreted as stripped of nutrients, so we decided not to use it.
  • “Serving Suggestion.” We added this callout to the front of the package and made sure it met the minimum font size requirements.

The Result!! I love how it looks after these compliance updates.

Diving into the back of the package… turns out almost every line of copy needed some sort of update.

Some of the biggest changes included:

  • Font size matters everywhere. Every required statement has minimum font size requirements based on the height of a lowercase “o.” I am going to bring a ruler to the grocery store to test this one...
  • You can’t call something “Low Calorie” unless it actually qualifies. We had twice the calories allowed for that claim. LOL.
  • Our comparison to fast-food fries needed much more documentation. Claims like “70% fewer calories” require a qualifying reference food, standardized serving sizes, supporting data, and ongoing verification. In other words, not worth it!
  • We couldn’t claim our fries were naturally rich in nutrients without meeting the FDA requirements and having documentation to support those claims.
  • “Keep ingredients real.” Even though this type of statement can be allowed, it’s considered subjective and could be viewed as misleading.
  • Be VERY careful using the word “healthy.” Even phrases like “put health first” can be interpreted as implied health claims.
  • We removed references to avocado oil being nutrient-rich. The amount of oil in the product simply isn’t enough to support that type of claim.
  • Our sea salt description also needed updating. Since we’ve actually switched to Redmond Real Salt (YAH!), this copy changed anyway.

We still had a beautiful bag with great copy after these changes:

A few more things we learned on the "boring" side of packaging:

  • “Manufactured by” is optional and only used if Naked Fries is manufacturing the product. Otherwise, it would be “Manufactured for” or “Distributed by” to indicate that a co-manufacturer is making the product.
  • Ensure the UPC (Aka the barcode) is appropriate format and size for GS1 Standards.
  • Ensure there is a place available for date and lot code information that is visible to consumers. This is the expiration stamp.
  • Ensure your cooking instructions are validated to allow the product to reach 165F and that the testing is documented.
  • Number of Fries is required for the Serving size - “3 oz (85 g/ ____ pieces)”. I look for this on other packages now…
  • The FDA does not recognize statements such as “Manufactured in a facility…” as a substitute for Good Manufacturing Practices. This statement does not protect the company from litigation if a consumer has a reaction and it must be true and not misleading. Do not state all allergens as a catch all unless they truly are used in the facility and the QA team recommends this statement. So the Manufactured in a facility with allergens that we see on packaging doesn’t actually do anything to protect you? This was news.
    • The “Manufactured in…” statement must list the specific tree nuts, fish and shellfish.
    • The “Manufactured in…” statement should list the allergens in alphabetical order.

As we were building Naked Fries, this was probably the biggest shock to us as I was not familiar with these rules and regulations. Now I always notice when other CPG brands might not be compliant… I say might because I am still not 100% sure what all the rules and regulations are.

As I said in the beginning, if you are building a CPG brand make sure to do your due diligence and hire a Package Compliance Consultant… Or maybe there is AI for that now.

Want more behind-the-scenes updates? Follow the full Naked Fries journey on Substack.