ink, or typewriter, provided all such written matter is distinctly legible and on the principal label, as prescribed in Regulation 17.
James Wilson.
Secretary of Agriculture.
Washington, D. C., March 13, 1907.
(F. I. D. 58.)
THE LABELING OF PRODUCTS USED AS FOODS AND DRUGS AS WELL AS FOR TECHNICAL AND OTHER PURPOSES.
Frequent requests for information relative to the proper labeling of products bearing the names of foods and drugs, but used also for technical and other purposes, are received. The following are typical:
We will kindly ask you to advise us in regard to the new law that governs the line of
oils. We manufacture a compound product, so-called "turpentine," which contains
pure turpentine and a very fine petroleum product. It is used in most branches where
pure turpentine is used, with the exception of medicinal purposes, for which we do not
sell it.
We understand that if we were to sell any cottonseed oil so branded as to indicate that it was intended to be used as a food, as, for example, under the brand "Blank Salad Oil," it would be necessary to observe the requirements of the law referred to; but we are in doubt and would be glad to have your opinion as to whether a sale or shipment of this oil (for lubricating purposes) under the ordinary trade-brand of cottonseed oil, and without anything to indicate that it was of a quality suitable for use as a salad oil, would subject us to the provisions of the act.
During personal interviews the question of marking chemical reagents has also been
discussed.
Products used in the arts and for technical purposes are not subject to the food and drugs act. It is, however, a well-recognized fact that many articles are used indiscriminately for food, medicinal, and technical purposes. It is also well known that some products employed for technical purposes are adulterated or misbranded within the meaning of this act. Inasmuch as it is impossible to follow such products into consumption in order to determine to what use they are finally put, it is desirable that an article sold under a name commonly applied to such article for food, drug, and technical purposes be so labeled as to avoid possible mistakes. The ordinary name of a pure and normal product, whether sold for food, drug, technical, or other purposes, is all that is necessary. Pure cottonseed oil or turpentine may be sold without any restrictions whatever, whether such article is sold for food, medicinal, or technical purposes, but it is suggested that a cottonseed oil intended for lubricating purposes, or a so-called turpentine consisting of a mixture of turpentine and petroleum oils, used by the paint trade, be plainly marked so as to indicate that they are not to be employed for food or medicinal purposes. Such phrases as the following may be used: "Not for Food Purposes," "Not for Medicinal Use," or for "Technical Purposes Only," or "For Lubricating Purposes," etc.
In order to avoid complication it is suggested that chemical reagents sold as such be marked with such phrases as the following: "For Analytical Purposes," or "Chemical Reagent," etc.
James Wilson,
Secretary of Agriculture.
Washington, D. C., March 13, 1907.
