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Guide

Food labeling for US food trucks

A taco handed through the window is restaurant-style food. A sealed bottle of truck hot sauce, a bag of cookies, or a fridge burrito sold closed is packaged food and needs FDA particulars. Trucks get this wrong when they sell merch from a cooler using the same exemption they use for plated tacos.

Reviewed against official guidance.SourcesNot legal advice.

The short answer

A taco handed through the window is restaurant-style food. A sealed bottle of truck hot sauce, a bag of cookies, or a fridge burrito sold closed is packaged food and needs FDA particulars. Trucks get this wrong when they sell merch from a cooler using the same exemption they use for plated tacos.

Where this shows up in a real kitchen

Health departments focus on truck commissaries and handwashing. Labeling shows up when you bottle the salsa “because customers asked”. That bottle is a grocery item that happens to be sold from stainless steel.

The US rule

Plated/window food: local food code and allergen info on request. Packaged bottles and bags: FDA identity, quantity, ingredients, FALCPA, usually Nutrition Facts. Cottage-food may apply if you made the cookies at home and the state allows that venue.

How to apply it

Keep a line on the prep list: “sold open” vs “sold sealed”. Only the sealed line gets pack labels. If you sell the sauce in stores next month, the truck cooler label should already have been grocery-grade.

  1. Inventory sealed SKUs on the truck.
  2. Label them as packaged food before service.
  3. Train window staff on majors for plated items.
  4. Do not reuse plated-food thinking for bottled merch.

Worked example

Window: carnitas taco, no pack label, staff can say wheat tortilla, dairy crema. Cooler: 5 fl oz salsa roja with identity, net quantity, ingredients, address. Cookie bag: wheat, butter (milk), eggs. Three modes, one truck.

Checks that belong on this pack

CheckWhy it matters
Salsa bottles have net quantity in fl ozA truck logo is not 101.105.
Cookie bags name milk and wheatMerch is food.
No fake USDA stamp on vegetarian salsaJurisdiction still matters.
Allergen answers at the window match the recipesThe matrix on the commissary wall has to be this week’s.

Bottling salsa into unlabelled mason jars “for the regulars”

Regulars still have guests. Jars still leave the truck.

What LabelClear can and cannot print

Label the sealed merch like grocery food. Use the generator for those ingredients; do not pretend the taco ticket covers the jar.

Questions

Do I need Nutrition Facts on a taco?
Not as a packaged panel. Covered chains have menu calories. A taco is not a grocery pouch.
Can I sell unlabelled cookies if they are free?
A sealed cookie offered as a packaged takeaway is still a pack. A tray sample is different.
What about prepacked burritos for the 2am crowd?
Sealed burritos are packaged food. Label them before the rush.

Official sources

Everything on this page traces back to these. Where they and we disagree, they are right — tell us and we'll fix it.