Guide
Nutrition Facts label requirements (FDA)
Most FDA-packaged foods sold at retail need a Nutrition Facts panel in the current format: serving size, calories, added sugars, nutrients in the 2016 rule, and dual columns when the pack is clearly more than one serving. Cottage-food and small-business exemptions exist — they are paperwork tests, not vibes.
Reviewed against official guidance.SourcesNot legal advice.
The short answer
Most FDA-packaged foods sold at retail need a Nutrition Facts panel in the current format: serving size, calories, added sugars, nutrients in the 2016 rule, and dual columns when the pack is clearly more than one serving. Cottage-food and small-business exemptions exist — they are paperwork tests, not vibes.
Where this shows up in a real kitchen
A sealed cookie box at a Minnesota gas station is grocery food. The same cookie on a café plate is not. Brands skip Nutrition Facts because a cousin’s cottage-food page said they could. Then they start shipping nationwide on Shopify and the exemption no longer matches the business they became.
The US rule
21 CFR 101.9 sets the Nutrition Facts format. Serving sizes follow FDA’s Reference Amounts Customarily Consumed, not a “sensible portion” you prefer. Added sugars have their own line. Dual-column labeling applies to certain multi-serving packages. FDA’s nutrition labeling requirements page and the Food Labeling Guide show the current panel. USDA FSIS products use a related but distinct nutrition panel.
How to apply it
Lock the serving size from RACC before you calculate anything else. Weigh a serving of the food you actually sell. Run software or a lab for nutrient values; do not type competitor numbers. If you claim an exemption, keep the basis (sales, staffing, or package size) in writing. Recalculate when the recipe or piece weight changes.
- Look up the RACC for the food category, not a serving you like for macros.
- Weigh the piece or pour you actually pack.
- Generate or assay nutrient values from the current formula.
- Choose single-column or dual-column, then print a panel that matches 101.9.
Worked example
A 4 oz brownie sold as one unit: RACC for brownies is not “one huge bakery brownie if hungry”. If the piece is more than 200% of RACC, the pack may need dual-column per serving and per pack. Butter and sugar drive saturated fat and added sugars. A “keto” front claim does not let you hide added sugars on the back.
Checks that belong on this pack
| Check | Why it matters |
|---|---|
| Serving size uses FDA’s household measure plus grams | “1 brownie (85 g)” beats “1 serving” with no mass. |
| Added sugars are not folded into total sugars only | The 2016 format wants both lines. |
| Exemption file exists if the panel is missing | “We’re small” is not documentation. |
| Recipe changes trigger a new panel | A seasonal pecan version is a new food for nutrition math. |
Using a UK traffic-light or generic calorie line instead of Nutrition Facts
UK front-of-pack calories and FDA Nutrition Facts are different documents. A Natasha’s Law ingredients label is not a substitute for 21 CFR 101.9.
What LabelClear can and cannot print
LabelClear prints ingredients and allergen names. It does not generate Nutrition Facts. Use this page to know when you still need that panel.
Questions
Do I need a lab?
Are samples exempt?
What about alcohol calories?
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.
- Nutrition labeling requirementsU.S. Food and Drug Administration
- 21 CFR Part 101 — Food labelingeCFR / National Archives
- Food Labeling GuideU.S. Food and Drug Administration
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