BACKGROUND:

The Food and Drug Administration, since 1940, has consistently held that a mixture of canned peas and carrots is not a standardized article. Trade Correspondence (TC) 263 stated that such a mixture may be appropriately designated as "peas and carrots" or "carrots and peas" and that it is not necessary in such a mixture to state on the label the optional pea ingredient or the optional form of carrots.

In 1956, in response to an inquiry about a canned item consisting of Blair process peas and frozen diced carrots, we stated that "the name 'Peas and Carrots' should be followed by a complete ingredient statement" and "the fact that the carrots have been frozen is a material one which should be revealed." This opinion then evolved into the more recent policy that all labels for mixtures of canned peas and carrots should bear a complete ingredient statement.

Both TC 263 and recent policy are inconsistent with regulations *21 CFR 155.170(a)* and the following policy is designed to resolve this inconsistency.

POLICY:

No specific standard of identity has been established for a canned mixture of carrots and peas. However, the food is considered to be a mixture of the standardized ingredients if (1) prepared from the fresh succulent vegetables in accordance with the methods prescribed by the standards for peas 21 CFR *155.170(a)* and carrots 21 CFR *155.200* and (2) it contains only water and the optional ingredients permitted by the standards; provided that if the food contains the optional ingredient butter, it is present in a quantity of not less than three percent of the finished food. A food meeting the above conditions may be designated by an appropriate statement of identity that includes the optional form of the carrot ingredient unless such optional form designation may be omitted in accordance with the regulations of 21 CFR *101.3(c)*. The optional pea ingredient need not be included as part of the statement of identity.

The ingredients should be designated on the label in accordance with 21 CFR *101.4(a)* by statements naming the optional pea ingredient, the optional form of the carrot ingredient, and supplemented by statements showing the optional ingredients which are present. If ingredients not permitted by the standards of identity are used, the article must bear an appropriate statement of identity and a full listing of all ingredients.

*Material between asterisks is new or revised.*

Issued: 7/25/69

Reissued: 12/3/73

Revised: 10/1/80, 12/8/88