Guide
Food labeling for US ghost kitchens
A US ghost kitchen that only hands food to a courier for immediate eating behaves like a restaurant. The same kitchen’s sealed meal kits, grocery SKUs and vending-fridge bowls are packaged food. Delivery photos and in-app ingredient toggles do not replace a lid label on a sealed bowl.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
A US ghost kitchen that only hands food to a courier for immediate eating behaves like a restaurant. The same kitchen’s sealed meal kits, grocery SKUs and vending-fridge bowls are packaged food. Delivery photos and in-app ingredient toggles do not replace a lid label on a sealed bowl.
Where this shows up in a real kitchen
Virtual brands share fryers and sauces. The app says “no peanut” while the satay lives on the next make line. When you start selling heat-and-eat packs in a grocer’s freezer, FDA or FSIS labeling arrives overnight. UK ghost kitchens talk PPDS; US ones should talk packaged vs restaurant.
The US rule
Immediate-consumption delivery: food-code + allergen info, not a grocery panel. Sealed retail packs: Part 101 + FALCPA + usually Nutrition Facts. Meat-heavy frozen meals may be FSIS. Marketplace platforms do not write your label.
How to apply it
Decide SKU by SKU. If the customer receives a sealed, labeled, reheated-later pack, label it as packaged food. If they receive a hot bag to eat now, train the line on majors. Shared sauces need a spec binder that every virtual brand actually uses.
- List virtual brands and which SKUs are eat-now vs heat-later.
- Label heat-later SKUs as packaged food.
- Share one allergen source of truth across virtual menus.
- Re-evaluate when a brand goes into grocery.
Worked example
Brand A: hot burgers in 20 minutes, no pack label. Brand B from the same line: 12 oz mac-and-cheese cups in a Target fridge — wheat, milk, identity, net weight, Nutrition Facts, address. Same steamer, two legal modes.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| App allergens match the make sheet | A toggle is not a spec. |
| Frozen grocery cups have panels | DoorDash packaging is not a Nutrition Facts exemption. |
| Peanut satay is not on the “no peanut” brand’s sealed SKU | Shared lines need physical rules. |
| Address on grocery cups is a real place of business | A brand name in an app is not 101.5. |
Using the restaurant exemption on a vending-fridge bowl
If it sits sealed for hours with a price, it is packaged food.
What LabelClear can and cannot print
For sealed grocery or fridge SKUs, draft ingredients and allergen names, then add US net weight and Nutrition Facts. Eat-now bags still need trained people.
Questions
Does Uber Eats require FDA labels?
Are ghost kitchens FSIS?
Can I put ingredients only in the app?
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.
- Food Labeling GuideU.S. Food and Drug Administration
- Food allergiesU.S. Food and Drug Administration
- Labeling — FSIS compliance guidanceUSDA Food Safety and Inspection Service
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