USDA relies on electronic GTIN records published by its contracted suppliers as the definitive product specification. Required published attributes include a full ingredient list, meal crediting, and a facsimile of the CN Label when applicable.
These electronic GTIN records are used during an Administrative or Procurement Review and matched against invoices or receiving documents for product codes and line-item descriptions. This process verifies receipt of these products verifying compliance with requirements for reimbursable meals. Photographs of CN labels on physical products are not required and are less likely to be accurate.
The issue was clarified in a USDA policy memos. Here are some helpful links:
Administrative Reviews Using Electronic “Watermark” Copies of CN Labels
GDSN Electronic Records Appear in USDA Databases
USDA is publishing data from manufacturers to populate the USDA Foods Database and Database and Child Nutrition Database (CNDB).
Read Here
Procurement Guidelines for Recipient Agencies
The Global Trade Item Number (GTIN) is to food service what the UPC is to retail groceries. Your procurement program should request GTIN technology during the solicitation process.