Corn Products Refining Co. v. Eddy

Background

An Illinois company manufactured and sold a table syrup called “Mary Jane,” shipping it in original sealed cans with its own label to Kansas wholesalers. The Kansas State Board of Health declared the syrup misbranded under a state law and Regulation 6, which required syrups that are compounds or blends to carry the word “compound” and state the percentage of each ingredient. The company sued, claiming the rule conflicted with the Commerce Clause, the federal Food and Drugs Act, and the Fourteenth Amendment by forcing disclosure of a secret formula. A district court sided with the company, but the Kansas Supreme Court reversed, and the case reached the U.S. Supreme Court.

Reasoning

The Court addressed whether the Kansas rule unlawfully burdened interstate commerce, conflicted with the federal Food and Drugs Act, or violated due process by taking trade secrets. Applying earlier precedent (especially Savage v. Jones), the Court held that a reasonable, non-discriminatory state requirement to disclose ingredients and percentages to prevent deception does not conflict with the federal statute. The Court also rejected the claim that a manufacturer has a constitutional right to sell without providing fair information; disclosure rules aimed at protecting buyers are a valid exercise of state police power.

Real world impact

The ruling permits Kansas to enforce its labeling rule against the syrup even when shipped in original packages from another State, so long as the regulation is reasonable and non-discriminatory. Manufacturers selling proprietary foods in Kansas must disclose ingredients and percentages as required or face enforcement. The decision follows existing precedent and does not change federal labeling law.