A label is a legal document that happens to be pretty. Once your product goes into a package and onto a shelf, federal law governs what has to appear on it, where, and how large. The rules are not complicated, but they are specific, and almost every first label we see from a new brand is missing at least one required element.
Get this right before you order five thousand of anything.
The five required elements
FDA labeling for packaged food breaks into two zones: the principal display panel (the part the customer sees on the shelf) and the information panel (usually the back or the panel immediately to the right of the PDP).
1. Statement of identity: principal display panel
The common name of the food, in bold type, in a size reasonably related to the most prominent printing on the panel. “Chocolate chip cookies.” “Cold brew coffee concentrate.” Your brand name is not a statement of identity: “Midnight Crunch” tells a regulator nothing about what is in the bag.
2. Net quantity of contents: principal display panel
In the bottom 30% of the panel, in both US customary and metric units: ounces and grams for solids, fluid ounces and milliliters for liquids. This is the element small brands forget most often, and it is the easiest one for an inspector to spot from across a room.
3. Ingredient statement: information panel
Every ingredient listed by its common name in descending order by weight. Sub-ingredients of a compound ingredient get declared in parentheses: chocolate chips (sugar, chocolate liquor, cocoa butter, soy lecithin). Colors and certain additives have specific naming requirements. No proprietary blends, no “secret spices.”
4. Allergen declaration: information panel
US law requires clear declaration of the major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame, sesame having been added as the ninth major allergen by federal law effective January 2023. Declare them either inside the ingredient list in parentheses or in a separate “Contains” statement immediately after it. Tree nuts must be specified by type (almonds, pecans) rather than lumped together.
“May contain” and “made in a facility that also processes” statements are voluntary, not a substitute for a required declaration, and not a shield if an allergen is actually an ingredient. If you’re producing in a shared kitchen, know your facility’s allergen handling practices and describe them accurately.
5. Name and place of business: information panel
The name and address of the manufacturer, packer, or distributor. If the company named isn’t the manufacturer, the line has to say so: “Distributed by” or “Manufactured for.” A city, state, and ZIP is generally enough if your street address is listed in a public directory.
When Nutrition Facts are required
Nutrition labeling is required for most packaged foods, but the FDA provides exemptions that many small producers qualify for. The two that matter most:
- The small business exemption: for companies with a low number of full-time equivalent employees and low annual unit sales of the product. Claiming it generally requires filing an annual notice with the FDA; it is not automatic just because you’re small.
- The low-volume exemption: for businesses with few employees selling a small number of units of a given product per year, also requiring notice.
Two things void any exemption instantly. First, making a nutrient content or health claim(“low sugar,” “high protein,” “good source of fiber”) obligates you to carry a full Nutrition Facts panel. Second, many retail and wholesale buyers require a Nutrition Facts panel as a condition of shelf space regardless of what the law says.
If you need a panel, you can either send product to a lab for analysis or use recognized nutrition analysis software built on USDA data. Software is cheaper and acceptable for most products; lab analysis is more defensible and sometimes required by a buyer.
Category-specific requirements
- Cottage food products. Florida requires a specific disclosure statement that the product was made in a cottage food operation not subject to Florida’s food safety regulations. Use the exact wording FDACS publishes. See our cottage food guide.
- Unpasteurized juice. Packaged juice that has not been processed to reduce pathogens generally requires a specific warning statement on the label.
- Products with dairy, and frozen desserts. Standards of identity govern what can be called “ice cream” versus other frozen dessert names, based on milkfat content and overrun.
- Coffee. Roasted whole bean and ground coffee has relatively light requirements; bottled ready-to-drink coffee is a packaged beverage and carries the full set.
- Organic, kosher, gluten-free, and similar claims. Each is governed by its own standard or certification. “Gluten-free” in particular is a defined FDA claim with a specific threshold, not a marketing adjective.
Claims that create risk
Health claims are the fastest way for a small brand to get a letter. Avoid anything suggesting your product treats, prevents, cures, or mitigates a disease: that language turns a food into an unapproved drug in the FDA’s eyes. Be careful with detox, immunity, and weight-loss language in the juice and wellness space, where it is endemic and where enforcement attention is highest.
“Natural,” “artisan,” and “small batch” are largely unregulated but must still be truthful and not misleading. “Homemade” on a product made in a commercial facility is misleading and worth avoiding.
Practical advice before you print
- Proof at final size. Print the label at actual size and read it. Type that looks fine on a monitor is often below the minimum legible size on a 2-inch jar.
- Order short runs first. Digital label printing is cheap in small quantities. Do not order a year of inventory on version one.
- Leave room for a barcode. If wholesale is anywhere in your future, buy a real GS1 prefix rather than a resold single code: retailers check.
- Put a lot code and date on every unit. Not usually required, but if you ever have to recall something, a lot code is the difference between pulling one batch and pulling everything.
- Keep a labeled sample of every version. With the date it went into use.