My response is:
What's there to think about, they are ingredients of the product and should
have been declared in the ingredient statement in the first place.
Declaration of all ingredients of a multiple component food in descending
order of predominance has been are requirement of the Food Drug and Cosmetic
Act for a long time. Section 403 (i) (2) of the act states that a food is
misbranded unless it's label bears, "... in case it is fabricated from two or
more ingredients, the common or usual name of each such ingredient.."
The labeling regulations found in Title 21 of the Code of Federal Regulations
further explain this requirement as follows:
21 CFR Part 101.4 Food; designation of ingredients.
(a)(1) Ingredients required to be declared on the label or labeling of a
food, including foods that comply with standards of identity, except those
ingredients exempted by 101.100, shall be listed by common or usual name in
descending order of predominance by weight on either the principal display
panel or the information panel in accordance with the provisions of 101.2.
Daryl Thompson
Food and Drug Administration