Legislation and Regulation Professor Saiger Spring 2016, Sections 9–10 Take-home Exercise 2: Intra-agency Memorandum Scenario Hampton Creek, a food company that makes plant-based egg substitutes, markets a food item under the brand name “Just Mayo.” “Just Mayo” is a substitute for mayonnaise that meets the requirements of a vegan diet. Ordinary mayonnaise contains egg yolks, which vegans do not eat. “Just Mayo” uses only plant foods to create a sauce that approximates the taste and texture of ordinary mayonnaise. Hampton Creek sells two flavors of “Just Mayo”: regular and “sriracha.” “Sriracha” is the name of a condiment based upon spicy peppers. On August 12, 2015, William A. Correll, Jr. sent a “Warning letter” to Hampton Creek. Correll is the Director of the Office of Compliance in the Center for Food Safety and Applied Nutrition. The Center for Food Safety and Applied Nutrition is a division of the United States Food and Drug Administration (FDA). The FDA is a unit of the United States Department of Health and Human Services (DHHS). The letter asserts that both “Just Mayo” flavors may not be sold in the United States under its current brand name or with its current label, pursuant to the Food, Drug, and Cosmetic Act (FDCA) and its associated regulations. Mr. Correll’s office was first made aware of the potential noncompliance of Just Mayo with food labeling and marketing law because of a lawsuit, alleging noncompliance by Hampton Creek, filed by the Unilever Corporation. Unilever is the leading American manufacturer of ordinary, egg-based mayonnaise. Unilever’s mayonnaise is sold under the brand names “Hellmann’s” and “Best Foods.” In April 2015, Unilever dropped its lawsuit, without prejudice to its ability to refile. After it received the warning letter, Hampton Creek conducted a negotiation with the Office of Compliance. Hampton Creek submitted a revised label to the Office. This new label, among other things, retained the original brand name “Just Mayo”; retained the original logo, which includes a picture of an egg; enlarged and made more prominent the words “egg-free”; and offered a definition of the word “just.” On December 18, 2015, the Office of Compliance sent a letter to Hampton Creek that stated that, with the new label, the “Just Mayo” products would be in compliance with the law and could lawfully be sold in the United States. Imagine that you are an attorney with the Office of the General Counsel in the Food and Drug Administration. Your office is reviewing this matter. Your supervisor has learned from a lawyer PACKET PAGE 1 at Unilever that Unilever intends to file a formal agency appeal with FDA alleging that Just Mayo, even with its new label, may not be lawfully sold in the United States. Unilever’s appeal will allege that the 18 December letter permits unlawful behavior. Your supervisor has also learned from lawyers at Hampton Creek that, should t ...

1. Legislation and Regulation
Professor Saiger
Spring 2016, Sections 9–10
Take-home Exercise 2: Intra-agency Memorandum
Scenario
Hampton Creek, a food company that makes plant-based egg
substitutes, markets a food item
under the brand name “Just Mayo.” “Just Mayo” is a substitute
for mayonnaise that meets the
requirements of a vegan diet. Ordinary mayonnaise contains
egg yolks, which vegans do not eat.
“Just Mayo” uses only plant foods to create a sauce that
approximates the taste and texture of
ordinary mayonnaise.
Hampton Creek sells two flavors of “Just Mayo”: regular and
“sriracha.” “Sriracha” is the name
of a condiment based upon spicy peppers.
On August 12, 2015, William A. Correll, Jr. sent a “Warning
letter” to Hampton Creek. Correll
is the Director of the Office of Compliance in the Center for
Food Safety and Applied Nutrition.
The Center for Food Safety and Applied Nutrition is a division
of the United States Food and
Drug Administration (FDA). The FDA is a unit of the United
States Department of Health and
Human Services (DHHS). The letter asserts that both “Just

2. Mayo” flavors may not be sold in the
United States under its current brand name or with its current
label, pursuant to the Food, Drug,
and Cosmetic Act (FDCA) and its associated regulations.
Mr. Correll’s office was first made aware of the potential
noncompliance of Just Mayo with food
labeling and marketing law because of a lawsuit, alleging
noncompliance by Hampton Creek,
filed by the Unilever Corporation. Unilever is the leading
American manufacturer of ordinary,
egg-based mayonnaise. Unilever’s mayonnaise is sold under the
brand names “Hellmann’s” and
“Best Foods.” In April 2015, Unilever dropped its lawsuit,
without prejudice to its ability to
refile.
After it received the warning letter, Hampton Creek conducted a
negotiation with the Office of
Compliance. Hampton Creek submitted a revised label to the
Office. This new label, among
other things, retained the original brand name “Just Mayo”;
retained the original logo, which
includes a picture of an egg; enlarged and made more prominent
the words “egg-free”; and
offered a definition of the word “just.”
On December 18, 2015, the Office of Compliance sent a letter
to Hampton Creek that stated that,
with the new label, the “Just Mayo” products would be in
compliance with the law and could
lawfully be sold in the United States.
Imagine that you are an attorney with the Office of the General
Counsel in the Food and Drug
Administration. Your office is reviewing this matter. Your

3. supervisor has learned from a lawyer
PACKET PAGE 1
at Unilever that Unilever intends to file a formal agency appeal
with FDA alleging that Just
Mayo, even with its new label, may not be lawfully sold in the
United States. Unilever’s appeal
will allege that the 18 December letter permits unlawful
behavior.
Your supervisor has also learned from lawyers at Hampton
Creek that, should the FDA
withdraw, alter, or materially supplement the 18 December
letter, Hampton Creek will allege that
its initial label is entirely lawful and seek to market its product
with that original label. Hampton
Creek, in other words, will allege that the 12 August letter
misstated and misapplied the FDCA
and its associated regulations.
Your supervisor tells you that the FDA has no preference
between Unilever and Hampton Creek.
Its only goal is correctly to apply the Act and its associated
regulations.
Your supervisor also tells you to do no research, and to use only
the packet of information that
she has prepared. That packet is attached to this document. It
includes:
(1) [starting at packet page 5] Relevant sections of the Food,
Drug, and Cosmetic Act

4. (2) [starting at packet page 17] Relevant sections of chapter 21
of the Code of Federal
Regulations (CFR)
(3) [starting at packet page 21] Warning letter from FDA to
Hampton Creek Foods, August
15, 2015
(4) [starting at packet page 25] Label for jars of Just Mayo
prior to August 15 letter (top
half of page); revised label after negotiation with FDA (bottom
half of page)
(5) [starting at packet page 26] Close-out letter from FDA to
Hampton Creek Foods,
December 18, 2015
(6) [starting at packet page 28] Amazon.com page for Just
Mayo, downloaded April 4,
2016
Each of these items is appended to this document. Some
material in items (1) and (3) has been
removed to make the problem more tractable; omissions are
indicated by white space.
Assignment
Your supervisor asks you to write a memo that:
1. States the argument Unilever is likely to make in its appeal;
2. States the arguments that Hampton Creek is likely to make
should FDA modify,
withdraw, or materially supplement its 18 December letter; and

5. 3. Recommends to the General Counsel how FDA should
respond to these arguments, and
what course it should adopt when regulating the sale and
labeling of Just Mayo products.
Write the memorandum.
PACKET PAGE 2
Instructions
1. This assignment is in the form of a memorandum to your
supervisor at the FDA. For the
purposes of the assignment, you should not use a complete
memorandum form. You should not
waste space on formalities, e.g., by providing a header or
restating the scenario at length. You
should begin your memo with a brief “short conclusion.” The
short conclusion should state in a
sentence or two what you have been asked to determine, and in
another sentence or two what you
conclude and why. The short conclusion is an abstract of the
memo that follows. The balance of
the memo should be the discussion section of the requested
memorandum.
This does not mean that your memo can be incoherent or
disorganized. A discussion section has
a beginning, middle, and end.
2. This is a “closed” assignment. It is to be completed using
only the materials in this packet

6. and concepts and cases we have studied in class. You should
not rely upon or discuss any
special knowledge you have regarding U.S. food law, the
policies and practices of the FDA, or
the mayonnaise industry.
Outside research is not permitted, except for the use of
dictionaries, your casebook, and
your classnotes. You may not rely upon any sections of the
United States Code not attached,
any sections of the Code of Federal Regulations not attached,
any legislative history not attached,
or any other materials. “Any other materials” in the previous
sentence is not meant to be limited
to materials like the United States Code or legislative history; it
really means any other materials.
You should be aware that I have fictionalized the statute, the
regulations, and other aspects of the
problem. Therefore, outside research, in addition to being
against the rules, is also likely to lead
you astray.
The requirement that you rely only upon materials in the packet
does not imply that everything in
the packet is relevant to the memorandum.
3. Audience. You should assume that your memorandum will
be read by FDA employees who
work in the world of Washington, but who may or may not be
lawyers. You should assume that
your reader is familiar but not intimate with the contents of the
assignment. So, you should set
out relevant statutory language, but you need not, for example,
explain what the U.S. Code, a
regulation, or the FDA is.

7. 4. Collaboration and groups. Groups of up to three students
may make a single submission.
Submissions will be graded without regard to the number of
submittors; each submittor in a
given group will receive the same grade on the assignment. The
word limits for this assignment
apply to each submission, without regard to the number of
submittors. I will not be able to assist
you with difficulties regarding the interactions or division of
labor within groups.
Students need not join a group if they prefer to complete this
assignment on their own.
PACKET PAGE 3
Your submission must be your own work. You may not discuss
this assignment or collaborate
with any persons outside of your group, if any. Once a group
begins to collaborate, it cannot
dissolve; otherwise its members will be in violation of the rule
that they not collaborate with
anyone outside their group.
5. Citation. Use the following citation conventions:
• Sections of the US Code or the Code of Federal Regulations:
Cite using chapter, section,
and subsections as relevant. Example: 5 U.S.C. § 553(b); 21
CFR § 130.3.
• Other materials in this packet: Cite as [short title] at [page

8. number]. Use the package
page number, not the page number internal to the document.
Examples: Scenario at 1;
Warning letter at 3; Amazon.com page at 2.
• Dictionaries: any form of citation that would allow me to find
the dictionary you used in
a library and that includes the word you looked up.
• Google searches: no citation necessary if you describe the
search in the text.
6. The word limitation on this assignment is 1,250 words. This
is approximately equivalent to
three and one-half double-spaced pages in a standard font with
standard margins. Use your word
processor to count the number of words in your memorandum.
Titles, headers, and citations
count as words. Page numbers and your name do not count as
words.
At the conclusion of your submission, add a paragraph that
reads “This answer contains x
words.” This paragraph does not count towards your word
count. This is a hard limit; I will not
read past 1,250 words.
7. Grammar, spelling, mechanics, and organization all count.
8. Your final paper should be uploaded to the TWEN
assignment dropbox no later than Friday,
22 April 2015 at 1:00 p.m. Submit the paper in MS-Word
format. Put your name at the top.
If you are collaborating with others, list all names at the top of
the paper in alphabetic order.
Give your paper a filename that consists of the surname of each

9. group member, in alphabetic
order (e.g., “Diller”; “Denno Saiger Teachout”).
Again, please make sure to list the names of all group members
at the top of the assignment
itself. (Names do not count towards word limitations.)
Late papers will be penalized. Extensions will be granted only
in unusual circumstances.
Extensions requested fewer than 72 hours in advance of the
duedate will be granted only in
extremely unusual circumstances.
9. Pace yourself. We will continue to proceed through the
assigned materials while you are
working on this assignment. So will your other classes. Please
come to (this and other) classes
prepared to discuss the assigned reading.
10. This assignment counts for 12.5% (one-eighth) of your
final course grade.
PACKET PAGE 4
21 USC 321
- 1 -
TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER II - DEFINITIONS

10. § 321. Definitions; generally
For the purposes of this chapter—
(a) (1) The term “State”, except as used in the last sentence of
section 372 (a) of this title, means
any State or Territory of the United States, the District of
Columbia, and the Commonwealth of
Puerto Rico.
(2) The term “Territory” means any Territory or possession of
the United States, including the
District of Columbia, and excluding the Commonwealth of
Puerto Rico and the Canal Zone.
(b) The term “interstate commerce” means
(1) commerce between any State or Territory and any place
outside thereof, and
(2) commerce within the District of Columbia or within any
other Territory not organized with
a legislative body.
(c) The term “Department” means Department of Health and
Human Services.
(d) The term “Secretary” means the Secretary of Health and
Human Services.
(e) The term “person” includes individual, partnership,
corporation, and association.
(f) The term “food” means
(1) articles used for food or drink for man or other animals,
(2) chewing gum, and
(3) articles used for components of any such article.
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11. Asaiger
Typewritten Text
* * * *
Asaiger
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21 USC 321
- 2 -
(k) The term “label” means a display of written, printed, or
graphic matter upon the immediate
container of any article; and a requirement made by or under
authority of this chapter that any word,
statement, or other information appear on the label shall not be
considered to be complied with unless
such word, statement, or other information also appears on the
outside container or wrapper, if any there
be, of the retail package of such article, or is easily legible
through the outside container or wrapper.
(l) The term “immediate container” does not include package
liners.
(m) The term “labeling” means all labels and other written,
printed, or graphic matter
(1) upon any article or any of its containers or wrappers, or
(2) accompanying such article.
(n) If an article is alleged to be misbranded because the
labeling or advertising is misleading, then in
determining whether the labeling or advertising is misleading
there shall be taken into account (among
other things) not only representations made or suggested by
statement, word, design, device, or any

12. combination thereof, but also the extent to which the labeling or
advertising fails to reveal facts material
in the light of such representations or material with respect to
consequences which may result from the
use of the article to which the labeling or advertising relates
under the conditions of use prescribed in
the labeling or advertising thereof or under such conditions of
use as are customary or usual.
PACKET PAGE 6
Asaiger
Typewritten Text
* * * *
21 USC 321
- 6 -
(ee) The term “Commissioner” means the Commissioner of
Food and Drugs.
PACKET PAGE 7
Asaiger
Typewritten Text
* * * *
21 USC 331
- 1 -

13. TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER III - PROHIBITED ACTS AND PENALTIES
§ 331. Prohibited acts
The following acts and the causing thereof are prohibited:
(a) The introduction or delivery for introduction into interstate
commerce of any food, drug, device,
or cosmetic that is adulterated or misbranded.
(b) The adulteration or misbranding of any food, drug, device,
or cosmetic in interstate commerce.
(c) The receipt in interstate commerce of any food, drug,
device, or cosmetic that is adulterated or
misbranded, and the delivery or proffered delivery thereof for
pay or otherwise.
(d) The introduction or delivery for introduction into interstate
commerce of any article in violation
of section 344, 355, or 360bbb–3 of this title.
(g) The manufacture within any Territory of any food, drug,
device, or cosmetic that is adulterated
or misbranded.
PACKET PAGE 8
Asaiger
Typewritten Text
* * * *
Asaiger
Typewritten Text
* * * *

14. 21 USC 341
NB: This unofficial compilation of the U.S. Code is current as
of Jan. 4, 2012 (see
http://www.law.cornell.edu/uscode/uscprint.html).
- 1 -
TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER IV - FOOD
§ 341. Definitions and standards for food
Whenever in the judgment of the Secretary such action will
promote honesty and fair dealing in the
interest of consumers, he shall promulgate regulations fixing
and establishing for any food, under
its common or usual name so far as practicable, a reasonable
definition and standard of identity,
a reasonable standard of quality, or reasonable standards of fill
of container. No definition and
standard of identity and no standard of quality shall be
established for fresh or dried fruits, fresh or
dried vegetables, or butter, except that definitions and standards
of identity may be established for
avocadoes, cantaloupes, citrus fruits, and melons. In prescribing
any standard of fill of container,
the Secretary shall give due consideration to the natural
shrinkage in storage and in transit of fresh
natural food and to need for the necessary packing and
protective material. In the prescribing of any

15. standard of quality for any canned fruit or canned vegetable,
consideration shall be given and due
allowance made for the differing characteristics of the several
varieties of such fruit or vegetable.
In prescribing a definition and standard of identity for any food
or class of food in which optional
ingredients are permitted, the Secretary shall, for the purpose of
promoting honesty and fair dealing
in the interest of consumers, designate the optional ingredients
which shall be named on the label.
Any definition and standard of identity prescribed by the
Secretary for avocadoes, cantaloupes,
citrus fruits, or melons shall relate only to maturity and to the
effects of freezing.
PACKET PAGE 9
21 USC 342
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TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER IV - FOOD
§ 342. Adulterated food
A food shall be deemed to be adulterated—
(a) Poisonous, insanitary, etc., ingredients
(1) If it bears or contains any poisonous or deleterious
substance which may render it injurious

16. to health; but in case the substance is not an added substance
such food shall not be considered
adulterated under this clause if the quantity of such substance in
such food does not ordinarily
render it injurious to health.1
(2)
(A) if it bears or contains any added poisonous or added
deleterious substance (other than
a substance that is a pesticide chemical residue in or on a raw
agricultural commodity or
processed food, a food additive, a color additive, or a new
animal drug) that is unsafe within
the meaning of section 346 of this title; or
(B) if it bears or contains a pesticide chemical residue that is
unsafe within the meaning of
section 346a (a) of this title; or
(C) if it is or if it bears or contains
(i) any food additive that is unsafe within the meaning of
section 348 of this title; or
(ii) a new animal drug (or conversion product thereof) that is
unsafe within the meaning
of section 360b of this title; or
(3) if it consists in whole or in part of any filthy, putrid, or
decomposed substance, or if it is
otherwise unfit for food; or
(4) if it has been prepared, packed, or held under insanitary
conditions whereby it may have
become contaminated with filth, or whereby it may have been
rendered injurious to health; or
(5) if it is, in whole or in part, the product of a diseased
animal or of an animal which has died
otherwise than by slaughter; or

17. (6) if its container is composed, in whole or in part, of any
poisonous or deleterious substance
which may render the contents injurious to health; or
(7) if it has been intentionally subjected to radiation, unless
the use of the radiation was in
conformity with a regulation or exemption in effect pursuant to
section 348 of this title.
(b) Absence, substitution, or addition of constituents
(1) If any valuable constituent has been in whole or in part
omitted or abstracted therefrom; or
(2) if any substance has been substituted wholly or in part
therefor; or
(3) if damage or inferiority has been concealed in any manner;
or
(4) if any substance has been added thereto or mixed or packed
therewith so as to increase its bulk
or weight, or reduce its quality or strength, or make it appear
better or of greater value than it is.
PACKET PAGE 10
Asaiger
Typewritten Text
* * * *
21 USC 343
- 1 -
TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT

18. SUBCHAPTER IV - FOOD
§ 343. Misbranded food
A food shall be deemed to be misbranded—
(a) False or misleading label
If
(1) its labeling is false or misleading in any particular, or
(2) in the case of a food to which section 350 of this title
applies, its advertising is false or
misleading in a material respect or its labeling is in violation of
section 350 (b)(2) of this title.
(b) Offer for sale under another name
If it is offered for sale under the name of another food.
(c) Imitation of another food
If it is an imitation of another food, unless its label bears, in
type of uniform size and prominence, the
word “imitation” and, immediately thereafter, the name of the
food imitated.
(d) Misleading container
If its container is so made, formed, or filled as to be misleading.
(e) Package form
If in package form unless it bears a label containing
(1) the name and place of business of the manufacturer,
packer, or distributor; and
(2) an accurate statement of the quantity of the contents in
terms of weight, measure, or numerical
count, except that under clause (2) of this paragraph reasonable
variations shall be permitted, and
exemptions as to small packages shall be established, by

19. regulations prescribed by the Secretary.
(f) Prominence of information on label
If any word, statement, or other information required by or
under authority of this chapter to appear on
the label or labeling is not prominently placed thereon with
such conspicuousness (as compared with
other words, statements, designs, or devices, in the labeling)
and in such terms as to render it likely to
be read and understood by the ordinary individual under
customary conditions of purchase and use.
(g) Representation as to definition and standard of identity
If it purports to be or is represented as a food for which a
definition and standard of identity has been
prescribed by regulations as provided by section 341 of this
title, unless
(1) it conforms to such definition and standard, and
(2) its label bears the name of the food specified in the
definition and standard, and, insofar as
may be required by such regulations, the common names of
optional ingredients (other than spices,
flavoring, and coloring) present in such food.
(h) Representation as to standards of quality and fill of
container
If it purports to be or is represented as—
(1) a food for which a standard of quality has been prescribed
by regulations as provided by section
341 of this title, and its quality falls below such standard,
unless its label bears, in such manner
and form as such regulations specify, a statement that it falls
below such standard;

20. (2) a food for which a standard or standards of fill of container
have been prescribed by regulations
as provided by section 341 of this title, and it falls below the
standard of fill of container applicable
thereto, unless its label bears, in such manner and form as such
regulations specify, a statement
that it falls below such standard; or
PACKET PAGE 11
21 USC 343
- 2 -
(3) a food that is pasteurized unless—
(A) such food has been subjected to a safe process or treatment
that is prescribed as
pasteurization for such food in a regulation promulgated under
this chapter; or
(B) (i) such food has been subjected to a safe process or
treatment that—
(I) is reasonably certain to achieve destruction or elimination
in the food of the most
resistant microorganisms of public health significance that are
likely to occur in the
food;
(II) is at least as protective of the public health as a process or
treatment described
in subparagraph (A);
(III) is effective for a period that is at least as long as the shelf
life of the food when
stored under normal and moderate abuse conditions; and
(IV) is the subject of a notification to the Secretary, including

21. effectiveness data
regarding the process or treatment; and
(ii) at least 120 days have passed after the date of receipt of
such notification by the
Secretary without the Secretary making a determination that the
process or treatment
involved has not been shown to meet the requirements of
subclauses (I) through (III) of
clause (i).
For purposes of paragraph (3), a determination by the Secretary
that a process or treatment has not
been shown to meet the requirements of subclauses (I) through
(III) of subparagraph (B)(i) shall
constitute final agency action under such subclauses.
(i) Label where no representation as to definition and standard
of identity
Unless its label bears
(1) the common or usual name of the food, if any there be, and
(2) in case it is fabricated from two or more ingredients, the
common or usual name of each
such ingredient and if the food purports to be a beverage
containing vegetable or fruit juice, a
statement with appropriate prominence on the information panel
of the total percentage of such
fruit or vegetable juice contained in the food; except that
spices, flavorings, and colors not required
to be certified under section 379e (c) of this title 1 unless sold
as spices, flavorings, or such colors,
may be designated as spices, flavorings, and colorings without
naming each. To the extent that
compliance with the requirements of clause (2) of this

22. paragraph is impracticable, or results in
deception or unfair competition, exemptions shall be established
by regulations promulgated by
the Secretary.
* * * *
PACKET PAGE 12
21 USC 350
NB: This unofficial compilation of the U.S. Code is current as
of Jan. 4, 2012 (see
http://www.law.cornell.edu/uscode/uscprint.html).
- 1 -
TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER IV - FOOD
§ 350. Vitamins and minerals
(a) Authority and limitations of Secretary; applicability
(1) Except as provided in paragraph (2)—
(A) the Secretary may not establish, under section 321 (n), 341,
or 343 of this title, maximum
limits on the potency of any synthetic or natural vitamin or
mineral within a food to which
this section applies;
(B) the Secretary may not classify any natural or synthetic

23. vitamin or mineral (or combination
thereof) as a drug solely because it exceeds the level of potency
which the Secretary determines
is nutritionally rational or useful;
(C) the Secretary may not limit, under section 321 (n), 341, or
343 of this title, the
combination or number of any synthetic or natural—
(i) vitamin,
(ii) mineral, or
(iii) other ingredient of food,
within a food to which this section applies.
(2) Paragraph (1) shall not apply in the case of a vitamin,
mineral, other ingredient of food, or food,
which is represented for use by individuals in the treatment or
management of specific diseases or
disorders, by children, or by pregnant or lactating women. For
purposes of this subparagraph,1 the
term “children” means individuals who are under the age of
twelve years.
(b) Labeling and advertising requirements for foods
(1) A food to which this section applies shall not be deemed
under section 343 of this title to be
misbranded solely because its label bears, in accordance with
section 343 (i)(2) of this title, all the
ingredients in the food or its advertising contains references to
ingredients in the food which are
not vitamins or minerals.
(2) The labeling for any food to which this section applies may
not list its ingredients which are
not dietary supplement ingredients described in section 321 (ff)
of this title

24. (i) except as a part of a list of all the ingredients of such food,
and
(ii) unless such ingredients are listed in accordance with
applicable regulations under
section 343 of this title. To the extent that compliance with
clause (i) of this subparagraph
is impracticable or results in deception or unfair competition,
exemptions shall be
established by regulations promulgated by the Secretary.
(c) Definitions
(1) For purposes of this section, the term “food to which this
section applies” means a food for
humans which is a food for special dietary use—
(A) which is or contains any natural or synthetic vitamin or
mineral, and
(B) which—
(i) is intended for ingestion in tablet, capsule, powder, softgel,
gelcap, or liquid form, or
(ii) if not intended for ingestion in such a form, is not
represented as conventional food
and is not represented for use as a sole item of a meal or of the
diet.
(2) For purposes of paragraph (1)(B)(i), a food shall be
considered as intended for ingestion in
liquid form only if it is formulated in a fluid carrier and it is
intended for ingestion in daily quantities
measured in drops or similar small units of measure.
PACKET PAGE 13

25. 21 USC 350
NB: This unofficial compilation of the U.S. Code is current as
of Jan. 4, 2012 (see
http://www.law.cornell.edu/uscode/uscprint.html).
- 2 -
(3) For purposes of paragraph (1) and of section 343 (j) of this
title insofar as that section is
applicable to food to which this section applies, the term
“special dietary use” as applied to food
used by man means a particular use for which a food purports or
is represented to be used, including
but not limited to the following:
(A) Supplying a special dietary need that exists by reason of a
physical, physiological,
pathological, or other condition, including but not limited to the
condition of disease,
convalescence, pregnancy, lactation, infancy, allergic
hypersensitivity to food, underweight,
overweight, or the need to control the intake of sodium.
(B) Supplying a vitamin, mineral, or other ingredient for use by
man to supplement his diet
by increasing the total dietary intake.
(C) Supplying a special dietary need by reason of being a food
for use as the sole item of
the diet.
Footnotes
1 So in original. Probably should be “paragraph”.
PACKET PAGE 14

26. 21 USC 393
- 1 -
TITLE 21 - FOOD AND DRUGS
CHAPTER 9 - FEDERAL FOOD, DRUG, AND COSMETIC
ACT
SUBCHAPTER X - MISCELLANEOUS
§ 393. Food and Drug Administration
(a) In general
There is established in the Department of Health and Human
Services the Food and Drug
Administration (hereinafter in this section referred to as the
“Administration”).
(b) Mission
The Administration shall—
(1) promote the public health by promptly and efficiently
reviewing clinical research and taking
appropriate action on the marketing of regulated products in a
timely manner;
(2) with respect to such products, protect the public health by
ensuring that—
(A) foods are safe, wholesome, sanitary, and properly labeled;
(B) human and veterinary drugs are safe and effective;
(C) there is reasonable assurance of the safety and
effectiveness of devices intended for
human use;
(D) cosmetics are safe and properly labeled; and
(E) public health and safety are protected from electronic
product radiation;

27. (3) participate through appropriate processes with
representatives of other countries to reduce
the burden of regulation, harmonize regulatory requirements,
and achieve appropriate reciprocal
arrangements; and
(4) as determined to be appropriate by the Secretary, carry out
paragraphs (1) through (3)
in consultation with experts in science, medicine, and public
health, and in cooperation with
consumers, users, manufacturers, importers, packers,
distributors, and retailers of regulated
products.
(c) Interagency collaboration
The Secretary shall implement programs and policies that will
foster collaboration between the
Administration, the National Institutes of Health, and other
science-based Federal agencies, to enhance
the scientific and technical expertise available to the Secretary
in the conduct of the duties of
the Secretary with respect to the development, clinical
investigation, evaluation, and postmarket
monitoring of emerging medical therapies, including
complementary therapies, and advances in
nutrition and food science.
(d) Commissioner
(1) Appointment
There shall be in the Administration a Commissioner of Food
and Drugs (hereinafter in this section
referred to as the “Commissioner”) who shall be appointed by
the President by and with the advice
and consent of the Senate.

28. (2) General powers
The Secretary, through the Commissioner, shall be responsible
for executing this chapter and for—
(A) providing overall direction to the Food and Drug
Administration and establishing and
implementing general policies respecting the management and
operation of programs and
activities of the Food and Drug Administration;
(B) coordinating and overseeing the operation of all
administrative entities within the
Administration;
PACKET PAGE 15
21 USC 393
- 2 -
(C) research relating to foods, drugs, cosmetics, devices, and
tobacco products in carrying
out this chapter;
(D) conducting educational and public information programs
relating to the responsibilities
of the Food and Drug Administration; and
(E) performing such other functions as the Secretary may
prescribe.
PACKET PAGE 16
Asaiger
Typewritten Text
* * * *

29. Selections from Code of Federal Regulations
21 CFR § 130.3. Definitions and interpretations.
(a) The definitions and interpretations of terms contained in [21
U.S.C. § 341] shall be
applicable also to such terms when used in regulations
promulgated under the act.
(b) If a regulation prescribing a definition and standard of
identity for a food has been
promulgated under [21 U.S.C. § 341] the act and the name
therein specified for the food
is used in any other regulation under [21 U.S.C. § 341] or any
other provision of the act,
such name means the food which conforms to such definition
and standard, except as
otherwise specifically provided in such other regulation.
(c) No provision of any regulation prescribing a definition and
standard of identity or
standard of quality or fill of container under [21 U.S.C. § 341]
shall be construed as in
any way affecting the concurrent applicability of the general
provisions of the act and the
regulations thereunder relating to adulteration and misbranding.
For example, all
regulations under [21 U.S.C. § 341] contemplate that the food
and all articles used as
components or ingredients thereof shall not be poisonous or
deleterious and shall be
clean, sound, and fit for food. A provision in such regulations
for the use of coloring or

30. flavoring does not authorize such use under circumstances or in
a manner whereby
damage or inferiority is concealed or whereby the food is made
to appear better or of
greater value than it is.
(d) Safe and suitable means that the ingredient:
(1) Performs an appropriate function in the food in which it is
used.
(2) Is used at a level no higher than necessary to achieve its
intended purpose in
that food.
* * * *
(e) [21 U.S.C. § 343(i)] of the act requires the listing of all
ingredients in standardized
foods. All ingredients must be listed in accordance with the
requirements of part 101 of
this chapter, except that where a definition and standard of
identity has specific labeling
provisions for optional ingredients, optional ingredients may be
declared in accordance
with those provisions.
PACKET PAGE 17
https://www.law.cornell.edu/cfr/text/21/101
https://www.law.cornell.edu/cfr/text/21/101

31. 21 C.F.R. § 130.8 Conformity to definitions and standards of
identity.
In the following conditions, among others, a food does not
conform to the definition and
standard of identity therefor:
(a) If it contains an ingredient for which no provision is made in
such definition and
standard, unless such ingredient is an incidental additive
introduced at a nonfunctional
and insignificant level as a result of its deliberate and
purposeful addition to another
ingredient permitted by the terms of the applicable standard and
the presence of such
incidental additive in unstandardized foods has been exempted
from label declaration as
provided in § 101.100 of this chapter.
(b) If it fails to contain any one or more ingredients required by
such definition and
standard;
(c) If the quantity of any ingredient or component fails to
conform to the limitation, if
any, prescribed therefor by such definition and standard.
PACKET PAGE 18
https://www.law.cornell.edu/cfr/text/21/101.100
21 C.F.R. § 169.140 Mayonnaise.

32. (a) Description. Mayonnaise is the emulsified semisolid food
prepared from vegetable
oil(s), one or both of the acidifying ingredients specified in
paragraph (b) of this section,
and one or more of the egg yolk-containing ingredients
specified in paragraph (c) of this
section. One or more of the ingredients specified in paragraph
(d) of this section may also
be used. The vegetable oil(s) used may contain an optional
crystallization inhibitor as
specified in paragraph (d)(7) of this section. All the ingredients
from which the food is
fabricated shall be safe and suitable. Mayonnaise contains not
less than 65 percent by
weight of vegetable oil. Mayonnaise may be mixed and packed
in an atmosphere in
which air is replaced in whole or in part by carbon dioxide or
nitrogen.
(b) Acidifying ingredients.
(1) Any vinegar or any vinegar diluted with water to an acidity,
calculated as
acetic acid, of not less than 21/2 percent by weight, or any such
vinegar or diluted
vinegar mixed with an optional acidifying ingredient as
specified in paragraph
(d)(6) of this section. For the purpose of this paragraph, any
blend of two or more
vinegars is considered to be a vinegar.
(2) Lemon juice and/or lime juice in any appropriate form,
which may be diluted
with water to an acidity, calculated as citric acid, of not less
than 21/2 percent by
weight.

33. (c) Egg yolk-containing ingredients. Liquid egg yolks, frozen
egg yolks, dried egg yolks,
liquid whole eggs, frozen whole eggs, dried whole eggs, or any
one or more of the
foregoing ingredients listed in this paragraph with liquid egg
white or frozen egg white.
(d) Other optional ingredients. The following optional
ingredients may also be used:
(1) Salt.
(2) Nutritive carbohydrate sweeteners.
(3) Any spice (except saffron or turmeric) or natural flavoring,
provided it does
not impart to the mayonnaise a color simulating the color
imparted by egg yolk.
(4) Monosodium glutamate.
(5) Sequestrant(s), including but not limited to calcium
disodium EDTA (calcium
disodium ethylenediamine- tetraacetate) and/or disodium EDTA
(disodium
ethylenediaminetetraacetate), may be used to preserve color
and/or flavor.
(6) Citric and/or malic acid in an amount not greater than 25
percent of the weight
of the acids of the vinegar or diluted vinegar, calculated as
acetic acid.
PACKET PAGE 19

34. (7) Crystallization inhibitors, including but not limited to
oxystearin, lecithin, or
polyglycerol esters of fatty acids.
(e) Nomenclature. The name of the food is “Mayonnaise”.
PACKET PAGE 20
4/3/2016 2015 > Hampton Creek Foods 8/12/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm458824.htm 1/4
U.S. Food and Drug Administration
Protecting and Promoting Your Health
Hampton Creek Foods 8/12/15
Department of Health and Human Services
Public Health Service
Food and Drug Administration
College Park, MD 20740
WARNING LETTER
AUG 12, 2015
VIA OVERNIGHT MAIL
Mr. Joshua Tetrick, Founder and Chief Executive Officer
Hampton Creek Foods, Inc.
371 Tenth Street

35. San Francisco, CA 94193
Re: 470327
Dear Mr. Tetrick,
The U.S. Food and Drug Administration (FDA) reviewed the lab
els and website labeling for your Just Mayo
and Just Mayo Sriracha products in June, 2015.
Based on our review, we have concluded that these products are
in violation of
section 403 of the Federal Food, Drug, and Cosmetic Act (the A
ct) [21 U.S.C. § 343] and its implementing
regulations found in Title 21, Code of Federal Regulations, Part
101 (21 CFR 101). You can find the Act and
FDA regulations through links on FDA’s home page at http://w
ww.fda.gov (http://www.fda.gov/).
The significant violations are as follows:
1.
* * * *
* * * *
PACKET PAGE 21
http://www.fda.gov/
4/3/2016 2015 > Hampton Creek Foods 8/12/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm458824.htm 2/4

36. 2.
3.
Your Just Mayo and Just Mayo Sriracha products are misbrande
d within the meaning of section 403(a)(1)
of the Act [21 U.S.C. § 343(a)(1)] in that they purport to be the
standardized food mayonnaise due to the
misleading name and imagery used on the label, but do not quali
fy as the standardized food mayonnaise as
described under 21 CFR 169.140. The name “Just Mayo” and an
image of an egg are prominently featured on
the labels for these products. The term “mayo” has long been us
ed and understood as shorthand or slang for
mayonnaise. The use of the term “mayo” in the product names a
nd the image of an egg may be misleading to
consumers because it may lead them to believe that the products
are the standardized food, mayonnaise,
which must contain eggs as described under 21 CFR 169.140(c).
Additionally, the use of the term "Just"
[1]
* * * *
PACKET PAGE 22
4/3/2016 2015 > Hampton Creek Foods 8/12/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm458824.htm 3/4
together with "Mayo" reinforces the impression that the product
s are real mayonnaise by suggesting that they

37. are "all mayonnaise" or "nothing but" mayonnaise. However, yo
ur Just Mayo and Just Mayo Sriracha do not
meet the definition of the standard for mayonnaise. According t
o the labels for these products, neither product
contains eggs. Additionally, the products contain additional ingr
edients that are not permitted by the standard
of identity for mayonnaise, such as modified food starch.
4.
Your Just Mayo and Just Mayo Sriracha products are misbrande
d within the meaning of section 403(g) of
the Act [21 U.S.C. § 343(g)] in that they purport to be a food fo
r which a definition and standard of identity has
been prescribed by regulation, but they fail to conform to such d
efinition and standard. Specifically, these
products purport to be mayonnaise by prominently featuring the
word “Mayo” on the labels, which has long
been used to refer to mayonnaise. Mayonnaise is a food for whic
h a definition and standard of identity has
been prescribed by regulation (see 21 CFR 169.140). According
to the standard of identity for mayonnaise,
egg is a required ingredient (21 CFR 169.140(c)); however, base
d on the ingredient information on the labels,
these products do not contain eggs. We also note that these prod
ucts contain additional ingredients that are
not permitted by the standard, such as modified food starch, pea
protein, and beta-carotene, which may be
used to impart color simulating egg yolk. Therefore, these produ
cts do not conform to the standard for
mayonnaise.
The above violations are not meant to be an all-inclusive list of
violations that may exist in connection with your
products or their labeling. It is your responsibility to ensure that
your products comply with the Act and its
implementing regulations. You should take prompt action to cor

38. rect the violations cited in this letter. Failure to
promptly correct these violations may result in regulatory action
without further notice, such as seizure and/or
injunction.
You should respond in writing within 15 working days from rec
eipt of this letter. Your response should outline
the actions you plan to take in response to this letter, including
an explanation of each step being taken to
correct the current violations and prevent their recurrence. Inclu
de any documentation necessary to show that
correction has been achieved. If you cannot complete corrective
action within 15 working days, state the
reason for the delay and the time within which you will complet
e the corrections.
You should direct your written reply to Anam Drumheller, Food
and Drug Administration, Center for Food
Safety and Applied Nutrition, 5100 Paint Branch Parkway, Offic
e of Compliance (HFS-608), Division of
Enforcement, College Park, Maryland 20740-3835. If you have
any questions regarding this letter, you may
contact Ms. Drumheller via email at [email protected]
* * * *
PACKET PAGE 23
mailto:[email protected]
4/3/2016 2015 > Hampton Creek Foods 8/12/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm458824.htm 4/4
(mailto:[email protected]).

39. Sincerely,
/S/
William A. Correll, Jr.
Director
Office of Compliance
Center for Food Safety
and Applied Nutrition
cc: FDA San Francisco District
PACKET PAGE 24
mailto:[email protected]
PACKET PAGE 25
4/3/2016
2015 > Hampton Creek Foods - Close Out Letter 12/18/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm478309.htm 1/2
U.S. Food and Drug Administration
Protecting and Promoting Your Health
Hampton Creek Foods - Close Out
Letter 12/18/15
Department of Health and Human Services

40. Public Health Service
Food and Drug AdministrationCollege Park, Maryland 20740
December 18, 2015
Josh Tetrick, Founder and Chief Executive Officer
Hampton Creek Foods, Inc.
371 Tenth Street
San Francisco, CA 94193
Dear Mr. Tetrick:
The Food and Drug Administration has completed an evaluation
of your firm's corrective actions in response
to our Warning Letter issued August 12, 2015. Based on that ev
aluation, we conclude that you have
satisfactorily addressed the violation(s) contained in the Warnin
g Letter. Future FDA inspections and
regulatory activities will further assess the adequacy and sustain
ability of these corrections.
This letter does not relieve you or your firm from the responsibi
lity of taking all necessary steps to assure
sustained compliance with the Federal Food, Drug, and Cosmeti
c Act and its implementing regulations or with
other relevant legal authority. The Agency expects you and your
firm to maintain compliance and will continue
to monitor your state of compliance. This letter will not preclud
e any future regulatory action should violations
be observed
during a subsequent inspection or through other means.
Sincerely,
/S/

41. William A. Correll, Jr.
Director
PACKET PAGE 26
4/3/2016
2015 > Hampton Creek Foods - Close Out Letter 12/18/15
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/ucm478309.htm 2/2
Office of Compliance
Center for Food Safety
and Applied Nutrition
More in 2015
(/ICECI/EnforcementActions/WarningLetters/2015/default.htm)
PACKET PAGE 27
http://www.fda.gov/ICECI/EnforcementActions/WarningLetters/
2015/default.htm
4/3/2016
Hampton Creek Just Mayo - Original - 8 oz: Amazon.com: Groc
ery & Gourmet Food
http://www.amazon.com/Hampton-Creek-Just-Mayo-Original/dp
/B00KBD7F7W 1/6
+ +
Frequently Bought Together

42. Total price: $24.03
Add all three to Cart
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These items are shipped from and sold by different sellers. Sho
w details
This item:Hampton Creek Just Mayo - Original - 8 oz $4.99
($1.66 / Count)
Hampton Creek, Just Mayo, Original, Gluten Free, Soy Free, Eg
g Free, 30oz Jar (Indivdual) $12.56
Vegan Parmesan Cheese $6.48 ($1.62 / oz)
Hampton Creek Just Mayo - Original - 8 oz from Hampton Cree
k
38 customer reviews | 5 answered questions
About the Product
Hampton Creek
Just Mayo
Original
8oz Bottle
Submit Submit
Submit Submit
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43. Price: $4.99 ($1.66 / Count) + $4.49 shipping
Note: Not eligible for Amazon Prime.
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Get it Sooner. Estimated delivery on April 5 - 8 when you choos
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4/3/2016
Hampton Creek Just Mayo - Original - 8 oz: Amazon.com: Groc
ery & Gourmet Food
http://www.amazon.com/Hampton-Creek-Just-Mayo-Original/dp

48. /B00KBD7F7W 2/6
Product Description
Hampton Creek, Just Mayo, Original, Gluten Free, Egg Free, So
y Free, 8oz Container (Pack of 3)
Product Details
Item Weight: 1.9 pounds
Shipping Weight: 2 pounds (View shipping rates and policies)
Domestic Shipping: Currently, item can be shipped only within t
he U.S. and to APO/FPO addresses. For APO/FPO shipments, pl
ease check with
the manufacturer regarding warranty and support issues.
International Shipping: This item is not eligible for internationa
l shipping. Learn More
ASIN: B00KBD7F7W
UPC: 859660004176
Average Customer Review: (38 customer reviews)
Important Information
Indications
Nutrition Facts Serving size: 1 tablespoon Nutrient Qty %DV C
alories 90 Calories from Fat 90 Total Fat 11 g 17% Saturated Fa
t 1 g 5% Sodium 65 mg 3% Is or
Contains Kosher Is or Contains Gluten Free ServingSize-InGra
ms 14 g
Ingredients
Non-GMO Expeller-Pressed Canola Oil, Filtered Water, Lemon
Juice, White Vinegar, 2% or Less of the Following: Organic Sug

49. ar, Salt, Apple Cider Vinegar, Pea
Protein, Spices, Garlic, Modified Food Starch, Beta-Carotene, C
alcium Disodium EDTA (to Preserve Freshness).
Directions
Just Mayo. Flavors unleashed. Non­GMO; Cholesterol­free; Veg
an; Egg-free; Dairy­free; Soy­free; Lactose­free; Gluten­free; K
osher; No artificial colors or flavors.
Legal Disclaimer
Actual product packaging and materials may contain more and d
ifferent information than what is shown on our website. We reco
mmend that you do not rely solely on
the information presented and that you always read labels, warn
ings, and directions before using or consuming a product. Please
see our full disclaimer below.
Customers Viewing This Page May Be Interested In These Spon
sored Links (What's this?)
1. Just Mayo -
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www.thrivemarket.com/Just-Mayo
2.
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- Try The Delicious Taste Of Organic. Discover Best Foods®
Organic Today!
www.bestfoods.com/Organic-Mayo
Ad feedback
Customer Questions & Answers
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Question: Is it produced in China?
Hampton Creek Just Mayo - Original - 8 oz
$4.99 ($1.66 / Count) + $4.49 shipping
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4/3/2016
Hampton Creek Just Mayo - Original - 8 oz: Amazon.com: Groc
ery & Gourmet Food
http://www.amazon.com/Hampton-Creek-Just-Mayo-Original/dp
/B00KBD7F7W 3/6
Top Customer Reviews
Just Mayo isn't just good, its "CRAZY" good
By Jackrabbit on September 4, 2014
Just Mayo isn't just good, its "CRAZY" good!! The first time I t
asted it I was hooked. I love the mayo
but more than that the company Hampton Creek and what they a
re doing for the planet. I can't wait for
their "beyond eggs" to hit the market. It is a game changer. No
more tofu scrabble eggs, YEAH!!!!!
1 Comment
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60. Best eggless mayonnaise!
By Jordan B. on September 22, 2014
I used to use Duke's mayonnaise, and this definitely isn't as goo
d, but compared to any vegan
mayonnaise I've had it's incredible. I was shocked when I first t
asted it. I had no idea an eggless
mayonnaise could be so good! I like it on sandwiches, but I've a
lso used it in salads and fruit salad.
Also Hampton Creek Foods is a company you can feel good sup
porting. Try it!
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Best store bought Mayo, vegan or regular!
By AKAK on January 8, 2015
After suffering through other "vegannaise" type mayonnaise I w
asn't excited to try another but the
clerk at the grocery store told me I'd be amazed . . . I was! My h
usband who has not food limitations
prefers this to Best Foods. I don't know how they do it but I wis
h they'd spread the word to
manufacturers of other egg free foods.
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Customer Reviews
38
4.3 out of 5 stars

61. Customer Images
Most Recent Customer Reviews
It's not Hellman's (the mayo I like
best), but it's better than other...
It's not Hellman's (the mayo I like best), but it's better
than other plain vegan mayos I have tried. Just a it
too sweet for me, but solid effort!
Published 1 day ago by Barbara Johnston
Didn't even know it was vegan for 6
months
I have been eating this mayonnaise for six months
and just discovered today that it is vegan. I didn't like
the taste of the regular mayonnaises my housemates
kept buying (brands... Read more
Published 23 days ago by Sarah Gillis
NOT, in a allergy free facility!
Enjoying this product depends if you are eating it with
allergy concerns.
Published 1 month ago by Nina
We love it with tuna salad-I do not
care for mayonaisse ...
A niece is severely allergic to eggs. This was the first
time she was ablet to eat tuna salad and or have
something on a sandwich or have potato salad-all
kinds of food. Read more
Published 1 month ago by DIANA C.
Hampton Creek
Great tasting mayo. Minus eggs! Recommended!
Published 1 month ago by telstar62

62. 1
vote
Answer: No. It is made in USA. This is not made in China.
By Yang on July 30, 2014
See more answers (1)
0
votes
Question: does this have to be refrigerated before opening?
Answer:
If you buy it off the shelf- NO if you buy it from the refrigerate
d section-yes. Some of their mayo contain preservatives and tho
se would be
the ones bought off the shelf. Either way they both taste AWSO
ME!!!!
By Jackrabbit on September 26, 2015
See more answers (4)
0
votes
Question:
Do you deliver outside the us? i'm based in scotland and have a
hankering for some good vegan mayo!
Answer:
Unfortunately no, Amazon is making it easier for some to make
that happen soon, but for most, it's the cross the border sales tha
t I think
most are iffy about.

63. By DM-Market, Online Groceries AP… on February 13, 2016
0
votes
Question: Is this Paleo?
Answer:
I would say technically, no, since it contains modified food star
ch and canola oil (which even if non-GMO, is a processed oil). I
think the
idea of paleo is to eat whole, non-processed food and grain-free.
This is, however, the best product out there if you have certain
food
allergies (especially eggs, gluten, dairy, s… see more
By Terina B. on September 5, 2015
See more answers (1)
See more answered questions (1)
5 star 76%
4 star 5%
3 star 3%
2 star 8%
1 star 8%
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70. 4/3/2016
Hampton Creek Just Mayo - Original - 8 oz: Amazon.com: Groc
ery & Gourmet Food
http://www.amazon.com/Hampton-Creek-Just-Mayo-Original/dp
/B00KBD7F7W 4/6
I'm not vegan- I like good mayonnaise
By Katie on February 27, 2015
I wouldn't have ever known this was eggless mayo if someone h
adn't told me. I'm not vegan- I like
good mayonnaise. This stuff is incredible. If buy this over what
I had previously been buying any day!
Wow! A girlfriend of mine used it with her kid who is allergic t
o everything too. Bonus!!
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Finally a healthy mayo that rivals the taste of Best Foods. Been
looking for
organic mayo and tried ...
By dandnic on December 2, 2014
Verified Purchase
Finally a healthy mayo that rivals the taste of Best Foods. Been
looking for organic mayo and tried
several but none tasted good to me. This one will do the trick as
I am no longer supporting big
corporations that source GMO ingredients and put other unhealt
hy ingredients in their products. Voting
with my dollars and happy to have found a product replacement

71. with Just Mayo!!! I recommend this
product!!! Just a note that the one I ordered came in a plastic sq
ueeze bottle instead of the glass jar
pictured...
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I'm sold on this!
By Buster Kitten on January 16, 2015
Verified Purchase
This product tastes just like mayo, and you will never know that
it is egg free, soy free, and gluten
free. Fabulous, because a family member cannot eat egg. I have
never found it in any store, so I
ordered a 3 pack from Amazon, and I have one at my office and
one at my home.
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Amazing mayo
By Dylan on June 9, 2014
This is the best mayo i think I've ever had. Definitely worth the
price of the product. It actually reminds
me of an Italian mayo called Calve
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72. Best vegan mayo
By Heather on February 18, 2015
the first vegan mayo I tried was Hampton creeks just mayo. The
n I thought of this being the standard
for all vegan mayos. So I use "nayonase" for a family gathering
cause I couldn't find Hampton creeks
mayo. Yuck! And I tried other brands, ew. Not good. So here I a
m back with the best brand ever. I
haven't had mayo in 5 years and to be honest, I kinda missed it.
So I am glad there is a cruelty free
vegan product that tastes like the real thing. This vegan mayo w
ill make even the most die hard mayo
lovers convert. You can find it even at Walmart now in the cond
iment section! So awesome!
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Four Stars
A good egg less mayo but expensive.
Published 2 months ago by David B. Center
Looking to transition to vegan? Love
mayo? GET THIS.
I originally decided at the end of last year, that after
years, I would return to vegetarianism. I had been a
vegetarian in high school and had to stop for personal
reasons. Read more
Published 2 months ago by Amazon Customer
Delish and NO Cholesterol!
Fantastic product...imagine Mayo MINUS cholesterol
yet with a wonderful flavor!!
This is it!!

73. Published 3 months ago by Barb M. McCarthy
Five Stars
GO VEGAN!!!
Published 3 months ago by Zach Bucci
Five Stars
Tastes just like regular, animal-product mayonnaise.
Published 4 months ago by R. robison
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