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How ArcheSync sources and maintains regulatory checks

This page explains which sources support ArcheSync's labeling checks, how each finding connects to its source, and how unclear cases are reported. Read it alongside the coverage limits for your product category. A citation makes a finding traceable; it does not by itself establish that every applicable requirement has been checked.

Source hierarchy.

When sources disagree, the higher one controls. Guidance never overrides a statute or regulation.

  • Statutes
    The Federal Food, Drug, and Cosmetic Act and related US Code sections, such as the allergen labeling provisions.
    e.g. 21 U.S.C. 343(w)
  • Regulations
    Title 21 of the Code of Federal Regulations, read from the current eCFR text.
    e.g. 21 CFR 101.9
  • Final FDA guidance
    Used to interpret a requirement and always labeled as guidance in a finding.
    e.g. FDA allergen Q&A, Edition 5
  • Federal Register actions
    Revocations and rule changes with their effective and compliance dates.
    e.g. 89 FR 55040
  • Draft or proposed material
    Never treated as a requirement.
    Labeled separately

What the food rule set covers.

The current rule set for food, supplement-routing and beverage labels has 105 checks, each built on one primary citation. Source text was retrieved between 2026-09-29 and 2026-10-02. Cosmetic checks are not in the rule set yet.

Computed from the rule set at build time. Example citations are the first distinct sources in each group.
AreaChecksScopeExample citations
Category-specific rules25Standards of identity, juice, water, product-type redirects21 CFR 108.25(c); 27 CFR 4.10; 21 U.S.C. 321(ff)(2)
Claims19Nutrient content, health, structure/function and implied claims21 CFR 101.54(g); 21 CFR 101.60(b); 21 U.S.C. 321(g)(1)
Ingredients and additives18Color additives, preservatives, sweeteners, revoked uses21 CFR 172.185; 89 FR 55040; 21 CFR 182.1180
Mandatory label elements13Identity, ingredients, panels, language, business line7 CFR 66.100; 19 CFR 134.11; 21 CFR 101.3
Nutrition labeling12Nutrition Facts content, format, serving size, exemptions21 CFR 101.9(c)(1)(i); 21 CFR 101.9(d)(7)(ii); 21 CFR 101.9(j)
Major food allergens6Declarations, species, exemptions, advisory statements21 U.S.C. 321(qq)(2); 21 U.S.C. 343(w)(1); 21 U.S.C. 343(w)
Import and registration context6Facility registration, prior notice and related context; mostly needs information beyond the artwork21 CFR 1.225(a); 21 CFR 1.502; 21 CFR 117.1
Packaging and net quantity6Net contents, multipacks, slack fill, food-contact notes21 CFR 174.5(d); 21 CFR 101.7(s); 15 U.S.C. 1453(a)(2)

Status definitions.

Each finding gets exactly one status. An unreadable field never becomes No issue; a check that could not be completed is reported as Review.

  • No issue

    The supported check did not identify an issue in the available evidence.

  • Review

    A conclusion requires clarification, additional evidence, or human interpretation.

  • Flag

    The available evidence indicates a potential issue against a cited requirement.

  • Info

    Relevant explanatory information. Not an assertion of a violation or a pass.

From evidence to provision.

A traceable example from the sample report, including what the software could not determine.

  • Evidence
    Soup base lists DRIED BONITO EXTRACT; the label reads "CONTAINS: WHEAT, SOY, MILK, EGG."
    noodle_cup_label.pdf
  • Check
    Does the "Contains" statement name the food source of every major food allergen in the ingredients?
    Allergen declaration
  • Provision
    Major food allergen labeling, with FDA guidance on complete "Contains" statements.
    FD&C Act §403(w)(1); FDA allergen Q&A D.6
  • FlagFinding
    "Contains" statement omits Fish (bonito).
    Status
  • Not determined
    Whether other allergens enter through shared equipment, which artwork cannot show.
    Outside the artwork

Versions, updates and corrections.

  • Rule-set version
    Each report records the rule-set version it was produced with. [TBD: confirm version stamp on reports (WO-05)]
    Reproducibility
  • Update workflow
    [TBD: source monitoring cadence, impact triage and release steps; publish only once the practice exists]
    Updates
  • Change validation
    [TBD: re-run of affected demonstration cases before a rule change is released]
    Validation
  • Review status
    The checks were drafted and cross-checked against source text but have not yet been individually reviewed by a qualified specialist. That is one reason ArcheSync is in Beta.
    Beta
  • Content owner
    [TBD: name of the person responsible for regulatory content, and qualified reviewers]
    Responsibility
  • Corrections
    Report an error: [TBD: corrections contact route]. Substantive corrections will be logged on this page.
    Corrections

Known limits.

What a label review cannot settle on its own: unreadable or missing panels; type sizes and placement that depend on package dimensions; classification questions (food, beverage or supplement); formulation, nutrient and substantiation evidence; and requirements outside the current rule set, including all cosmetic checks until cosmetic review opens.

Questions

Which sources are used?

Statutes and regulations first: the FD&C Act and other US Code sections, and Title 21 of the Code of Federal Regulations (with a few provisions from Titles 7, 9, 19 and 27, and one state law). FDA guidance is used to interpret them and is labeled as guidance. Every check names its source.

How are changes reviewed?

[TBD: the operating update workflow (monitoring cadence, review and release steps)]

How are uncertain or unsupported checks handled?

They are reported as Review, never as No issue. That covers text the software could not read, checks that need information beyond the artwork, and checks that are not automated yet.

Review your label before your next artwork revision.

Upload a PDF or image. Findings come back with the citation attached.

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Independent software. Not affiliated with FDA.