FDA warning letters are good resources for learning about food label regulations. They very clearly give examples on what causes ‘mislabeling.’ One such recent FDA warning letter makes many references to “metatags.” What is a meta tag?
According to WhatIs.Com:
“A meta description tag is a snippet of…code in a web page…that summarizes the content that is on the web page. The meta description is usually placed after the title tag and before the meta keywords tag. When optimizing a web page for search engines (SEO), it is considered a best practice to use meta description tags.”
Although meta tags are hidden from plain sight, it’s clear they are claims. — As the FDA points out in this case:
metatags [sic], which are used to bring consumers to your website, also include claims for… Alzheimer’s… glaucoma… impotence… mononucleosis… asthma… bed sores… benign prostatic hyperplasia… berberi… blood clot… chlamydia… ” and the list of meta tags goes on.
Examples of some of the labeling claims that provide evidence that your products are intended for use as drugs include…meta tags
So if you are going to use meta tags, on you website then treat them as if they were visibly printed on the actual product label because the FDA considers your website – even the stuff that’s hidden from plain sight – as part of your label and demonstrates intentions.