How to make a food label that meets FDA requirements

How to make a food label: the five required parts

A packaged food sold in the US needs five statements on its label: the name of the food (the statement of identity), the net quantity, the ingredient list, the major allergens, and the name and address of the manufacturer, packer or distributor. Federal law also requires that packaged foods and dietary supplements bear nutrition labeling unless they qualify for an exemption; the Nutrition Facts panel has its own rules and is covered on a separate page.

FDA splits the label into two areas. The principal display panel (PDP) is the part of a label that is most likely to be displayed, presented, shown, or examined under customary conditions of display for retail sale. The information panel is the label panel immediately to the right of the PDP. The table shows which part goes where and the main rule for each one.

Rules vary by state, county and city, and home-kitchen (cottage food) sellers often have extra label statements set by their state. This page covers the federal FDA rules and is general information, not legal advice.

Food labeling requirements for layout: front panel and information panel

FDA requires you to place the statement of identity, or name of the food, and the net quantity statement on the PDP. On a box, the PDP area is the height multiplied by the width of the front. On a jar or can, FDA uses 40% of the product of the height by the circumference.

The information panel holds the name and address of the manufacturer, packer or distributor, the ingredient list, nutrition labeling and any required allergy labeling. These statements go together on that panel. Information that is not required by FDA is considered intervening material, so it cannot sit between the required statements; for example, the UPC bar code is not FDA required labeling. If these statements appear on the PDP instead, they do not need to be repeated on the information panel.

• Type on the information panel and in the ingredient list must be at least 1/16 inch in height (based on the lower case “o”).
• Letters must not be more than three times as high as they are wide, and they must contrast with the background.
• Required statements appear in the English language. If any other language is used on the label, all required label statements must appear both in English and in the foreign language.

The statement of identity: what to call the food

The statement of identity is the name of the food on the front panel. FDA's order of preference is The name established by law or regulation first, then the common or usual name of the food. If the food has neither, use an appropriate descriptive name, that is not misleading.

In practice, that means "strawberry jam", "granola" or "chocolate chip cookies", and not only a brand or a product nickname. Brand names are not considered to be statements of identity. The name goes on the front in type at least 1/2 the size of the largest print on the label.

Example: if your brand is "Juniper Kitchen" and the product is a jar of oat granola, the front panel reads "Juniper Kitchen" and "Maple oat granola", with the food name in type at least half the height of the brand name if the brand name is the largest print.

Net quantity: how much is in the package

The net quantity statement tells the buyer how much food is in the package. It goes in the bottom 30 percent of the principal display panel. Labels show it in both metric (grams, kilograms, milliliters, liters) and U.S. Customary System (ounces, pounds, fluid ounces) terms.

The minimum type height depends on the area of the PDP. Measure the height of the lower case letter “o” or its equivalent, or the height of the upper case letters when only upper case letters are used.

Example: a jar 3 inches tall and 9 inches around has a PDP of about 10.8 square inches under the cylinder rule, so its net quantity statement falls in the second row of the table.

How to make an ingredient label

The ingredient list goes on the same label panel as the name and address of the manufacturer, packer or distributor. Work from your recipe by weight, not by volume or by cups.

1. Weigh every ingredient

   Write down the weight of each ingredient in one batch. The ingredient list order depends on weight, so a cup of flour and a cup of sugar are not equal.

2. Sort by weight

   List ingredients in descending order of predominance by weight: the heaviest first and the lightest last. FDA's own example reads “Ingredients: pinto beans, water, and salt”.

3. Use common names

   Name each ingredient the way a shopper knows it. FDA's guide gives the example of using the term “sugar” instead of the scientific name “sucrose.”

4. Break down compound ingredients

   If an ingredient is itself made of several ingredients, such as chocolate chips, its sub-ingredients may be declared parenthetically following the name of the ingredient, for example "chocolate chips (sugar, chocolate, cocoa butter, soy lecithin)".

5. Group the small ones if you want

   Ingredients at 2 percent or less by weight do not have to follow weight order if you list them at the end after a phrase such as “Contains __ percent or less of ______”.

6. Declare the allergens

   Name the food source of each major allergen In parentheses following the name of the ingredient, or Immediately after or next to the list of ingredients in a “contains” statement.

Ingredient list order and what can be left out

The ingredient list order is fixed by the weight of each ingredient in the food. Added water is listed by weight like any other ingredient, but if all of it is baked off or otherwise removed during processing, water need not be declared as an ingredient. If you change a recipe and the order of two ingredients flips, the label has to change too.

Example: a granola made with 400 g oats, 150 g maple syrup, 100 g almonds, 60 g sunflower oil, 5 g salt and 3 g cinnamon would read "Ingredients: Oats, maple syrup, almonds, sunflower oil, salt, cinnamon. Contains almonds."

An ingredient that is has no functional or technical effect in the finished product, then it need not be declared. That exception does not cover allergens: FALCPA labeling requirements apply to foods that are made with any ingredient, including flavorings, colorings, or incidental additives.

Allergen declarations on the ingredient label

Federal law names nine major food allergens: milk, eggs, fish, Crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Sesame became the 9th major food allergen, and the labeling rules apply to it as of January 1, 2023.

You can declare an allergen in one of two ways: In parentheses following the name of the ingredient, or Immediately after or next to the list of ingredients in a “contains” statement. For tree nuts, fish and shellfish you must name the specific kind: the law requires the type of tree nut (for example, almonds, pecans, walnuts), the species of fish (for example, bass, flounder, cod) and Crustacean shellfish (for example, crab, lobster, shrimp) to be declared, not only "tree nuts" or "fish". Allergen labeling has more detail than fits here, including cross-contact, which is a separate topic.

Name and address of the manufacturer, packer or distributor

The label must show the Name and address of the manufacturer, packer or distributor. If the name on the label is not the company that made the food, add a phrase that shows the relationship, such as “manufactured for” or “distributed by”.

The address needs a Street address if the firm name and address are not listed in a current city directory or telephone book, plus the City or town; d. State (or country, if outside the United States); and e. ZIP code. If you work from home and would rather not print your home address, check your state's cottage food rules before you choose an address for the label.

Food labeling requirements for small business

The five parts above apply to small producers as well as large ones. What changes for a small business is mostly the Nutrition Facts panel. FDA's small business exemption covers retailers with annual gross sales of not more than $500,000, with no notice to file. A separate low-volume exemption applies to a product when the firm has fewer than an average of 100 full-time equivalent employees and fewer than 100,000 units of that product are sold in a year, and for it a notice must be filed annually with FDA. The full rules are on a separate page.

Those exemptions have no effect on all other mandatory information, so the name, net quantity, ingredient list and name and address are still required. State and local rules can add their own label statements, especially for cottage food made in a home kitchen. Check your state health or agriculture department before you print, because rules vary by state and city. This page is general information, not legal advice.

1. Write the name of the food and the net quantity for the front panel.
2. Weigh your recipe and write the ingredient list in weight order.
3. Add allergen names in parentheses or a "Contains" line.
4. Add the name, city, state and ZIP of the business, with "Distributed by" or "Manufactured for" if needed.
5. Decide whether you need a Nutrition Facts panel or qualify for an exemption.
6. Check your state's extra label statements, then print a test label and measure the type.

Where Nation fits

Questions about food label requirements