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Alternate Protein Product Requirements

A CN label should have APP documentation attached with the application that shows how the APP meets the regulation. This includes: 

  1. Providing a statement that the APP meets the requirements found in Appendix A of 7 CFR 210, 220, 225, and 226.
  2. Showing that the product has been processed so that some portion of the non-protein constituents has been removed.
  3. Providing the Protein Digestibility Corrected Amino Acid Score (PDCAAS). The PDCAAS is required to be greater than 80% of casein and indicating how the PDCAAS was determined.
  4. Showing that the protein level is at least 18% by weight when fully hydrated or formulated.
  5. Providing the protein level of an APP on an “as-is” basis for the as purchased product. Protein is often provided on a moisture free basis (mfb) which is not the information FNS requires. 

Manufacturers should note that for products that were VPP before the regulation was changed that FNS will accept the VPP label stating the product name, hydration ratio, and as-is protein level until Dec. 31, 2001. After Dec. 31, 2001, all the above information required for APP must be presented for approval.

Page updated: March 04, 2024