FDA Subclass & PIC Definitions
The Food and Food-Related Subclasses
For products under Industry codes 02 – 50, subclass refers to the container type – the primary materials that contact and/or hold the product.
Food container materials are important to the FDA because they can affect food products in numerous ways. Food containers maintain freshness, prevent damage and spoilage, make the product more attractive, etc. Food containers can also contaminate the product through chemical migration, foreign objects, etc.
The materials used for containers by the food industry are varied depending upon the product, type of storage, physical character of the food, etc. Many materials and combinations of materials can be used for food containers. Only the common container materials are listed below and throughout the Product Code.
Containers should be coded by specifying the primary material that contacts and/or holds the product. For example, in many instances an inner coating or film may actually contact the food, such as coatings on the interior surfaces of metal cans or the coating inside paper boxes. But, in these two examples, the container type would be "metal" and "paper" respectively, since they are the primary container materials.
Examples of other container types are: a plastic bag or a paper bag within an outer box. In these two cases, the container types would be "plastic film" and "paper," respectively. For many containers, the primary container material may not be readily visible as in the case of lined boxes, laminated containers, etc. In these cases, an inspector may need to ask plant management for a sample of the product and then carefully examine the container. Import filers will have to obtain the information from the import documentation, Importer of Record or the manufacturer or shipper.
The table below gives you some examples of the type of containers that should be coded under the common container materials listed in the subclass.
| Subclass | Name | Container Types |
|---|---|---|
| A | Fabric Containers | Textile or fabric bag, stocking or casing, burlap, etc. |
| B | Ceramic, Earthenware | Ceramic jar, earthenware bottle, crock, jar, etc. |
| C | Glass | Glass containers with coated or uncoated aluminum lids; cork stoppers; lined or unlined plastic lids; coated, lined or bare steel-based plate lids; coated or uncoated tin lids, lined or unlined tin lids. |
| D | Laminated (flexible or rigid) | Laminated containers are a variety of different materials BONDED together, such as layered containers comprised of paper and foil, paper and plastic, etc. This includes laminated pouches and bags, and laminated tubes with plastic, cork-lined, foil-lined, laminated and aluminum lids. |
| E | Metal | Containers comprised of aluminum, tin or tinless steel-based material. Includes aluminum cans, trays, tubes and foil; and foil lines, loose or unbonded, within a paper bag, sack, pouch, etc. |
| F | Paper | Fiber (board) barrels, drums, pouches, sacks, bags, boxes, cartons, etc. Also includes tubes with aluminum ends. Note: includes wax paper, etc. |
| G | Plastic, Synth (flexible) | Plastic bags, pouches, wrappers, boil-in-bags, shrink packs, squeeze bottles or tubes with line/unlined tops, etc. Also includes plastic lines, loose or unbonded within a paper bag, sack, pouch, etc. |
| H | Nonflex Plastic, (rigid, or semi-rigid) | Rigid or semi-rigid plastic containers with plastic aluminum, steel-based, or tin lids. Also includes plastic trays or pans with foil, cellophane, paper or cardboard covers. |
| J | Wood | Wood barrel, cask, wheel, box, drum, etc. |
| M | Multiple | Use only when there is more than one type of food contact container of different materials. Examples: pizza mix kits, noodle and cheese dinners, etc. |
| V | Vacuum or Modified Atmosphere Packaging | Either gases have been removed (vacuum) or the air in the package or container is replaced by one or more gases, in various concentrations (modified atmosphere-packaging), before the package is commercially sterile but may be hermetically sealed. Product is not shelf stable (e.g., requires refrigeration or freezing). |
| W | Wax | Products with a wax covering such as cheese, vegetables, etc. (Excludes waxed paper) |
The Food-Related Process Indication Codes (PIC)
The Process Indicator Codes describes the process used in preparing a food product. There are 14 possible processes to choose from. The first decision to be made is whether or not a product is Unprocessed (Raw) or Processed (Packaged). The invoice or other product information that you may have should help you determine whether the product is unprocessed or processed.
If the product has not been processed, the appropriate Raw PIC (i.e., B, C or D) is used. Keep in mind that Raw refers to unprocessed and raw (e.g., fresh, and or in natural state). If the product has received any type of processing, the Raw PICs do not apply. For example, filleted, skinned, fresh fish; peeled or deveined shrimp; or smoked fish are processed foods. One of the processed PICs should be selected.
The most widely used PIC for processed foods is Packaged Food. However, when appropriate, a specific PIC should be utilized, such as, identifying the heat treatment used in preparing the finished produce (e.g., heat treated (cooked); pasteurized; commercially sterile; ultrapasteurized; or aseptic pack; or identifying other types of processing used. The invoice or other product information that you may have should help you determine the type of processing used.
Below is a brief definition of the PIC codes currently in use.
| Process Indicator Codes | Name | Process Type Definition/Explanation |
|---|---|---|
| B | Raw | Product is in its natural state, (e.g., fresh, raw and/or natural product). The product is NOT stored or transported refrigerated or frozen, but held in ambient temperatures (e.g., grains, nuts, or seeds, etc.) |
| C | Raw, Fresh Refrigerated | Product is in its natural state (e.g., fresh, raw and/or natural product). Includes such functions as waxing, polishing, etc. that make a raw product appear better (e.g., fresh product). The product may be fresh packaged and refrigerated or on wet ice. Includes de-headed "shell on" shrimp de-headed and/or gutted whole fish, etc. See also PIC "T." |
| D | Raw, Fresh Frozen | Product is in natural state (e.g., fresh, raw and/or natural product). The product may be fresh packaged and frozen. Includes frozen de-headed "shell-on" shrimp, de-headed and/or gutted whole fish, etc. See also PIC "T." |
| E | Commercially Sterile | Packed in hermetically sealed containers; then heated to achieve commercial sterility. Product is shelf stable. Examples of commercially sterile products include canned vegetables and canned fish products. Note: canned fruit, most tomato products, and pickled vegetable products do not fall within this process because they are not heated to achieve commercial sterility. |
| F | Aseptic Pack | Heated to achieve commercial sterility and packed using pre-sterilized containers and closures and then hermetically sealed. Examples of products that may be aseptically packed include single serving milk based drink product and single serving pudding products. |
| H | Dried Natural Or Artificial | The product is either dried naturally or by using heat, cold and/ or chemicals.Examples include raisins, dried fruit mixes, nonfat dry milk, etc. |
| I | Acidified | Packed in hermetically sealed containers; acids or acid foods added to low-acid food(s). May be heat treated or pasteurized. Product is shelf stable.Vegetables such as peppers, pickles and relish are acidified. |
| N | Heat Treated | Product or concentrate is heated or partially heated (e.g., baked, blanche, cooked, fried, boiled, etc.). The product is not commercially sterile but may be hermetically sealed. Product is not shelf stable (e.g., requires refrigeration or freezing). |
| O | Pasteurized | Product or concentrate is heated at a temperature of 145 F for 30 minutes or 161 F for 15 seconds. The process will destroy certain disease-producing organisms; destroy or reduce the number of spoilage organisms in certain foods. The product is not commercially sterile but may be hermetically sealed. Product is not shelf stable (e.g., requires refrigeration or freezing). Product labeling in most cases will reflect this process (e.g. crabmeat, apple cider, orange juice, egg nog, etc.). |
| P | Cultured Or Cured | The product is cultured, fermented, salted (brined), (pickled), smoked cured, sugar cured or has an enzymatic reaction which may be the result of naturally occurring enzymes or chemicals. Examples of cultured or cured products include sauerkraut, wine, aged cheese (hard or soft) and naturally fermented pickles. Note that this does not include products that have been processed by direct acidification (adding an acid ingredient, such as vinegar, directly to the product). Those products are coded as Acidified. |
| R | Irradiated | Product is irradiated. Irradiated products receive treatment with radiation as a method of preservation. This process is used infrequently. Without information from the manufacturer it is difficult to determine whether a product has been irradiated. Examples of products that may be processed in this manner are spices. |
| S | Ultrapasteurized | Product or concentrate is heated between 190-120 F or greater with exposure time from 1 second or greater. The process will destroy certain disease-producing organisms; destroy or reduce the number of spoilage organisms in certain foods. The product is not commercially sterile but may be hermetically sealed. Product is not shelf stable (e.g., requires refrigeration or freezing). Product labeling in most cases will reflect this process (e.g., coffee creamer, shelf-stable milk, etc.). |
| T | Packaged Food (Not commercially sterile) | These products are not commercially sterile but may be hermetically sealed (e.g., shelf stable fruit drink in cans, tomato juice, and pineapple juice). The product may or may not be shelf-stable (e.g., may be held ambient, refrigerated, or frozen). Processing of the finished product may include any of the following processes: Addition of sauces, breading, etc. Milling, grinding, or mixing of dry ingredients Filleting, skinning fresh fish, shucking shellfish Peeling, deveining raw shrimp |
Note: Filleted. Skinned, fresh fish or peeled/deveined shrimp is a processed food and will be in PIC Code "T"
For de-headed raw "shell-on" shrimp; gutted and/or de-headed whole fish, etc., use the following PIC codes as applicable: "raw, fresh, refrigerated" use code "C", "raw, fresh frozen" use code "D"