US food packaging label requirements: Nutrition Facts and allergens

If you sell packaged food in the United States, your label must follow the FDA's food labelling rules. The basics are well defined: five required elements, a standard Nutrition Facts panel and clear allergen declarations. The detail is where brands get caught out. This guide walks through the requirements and how to plan them into your packaging design.

It is a general overview for brands and designers, not legal advice. Meat, poultry and some egg products are regulated by the USDA rather than the FDA and have different rules. The FDA's Food Labeling Guide and 21 CFR Part 101, linked below, are the official references.

The two main label panels

US food labels are built around two panels:

• The principal display panel (PDP) is the part of the label most likely to be seen by consumers at the time of purchase, usually the front.
• The information panel is generally the panel immediately to the right of the PDP as the customer faces it. If that panel cannot be used, the next panel to the right is used.

Certain information must appear on the PDP, and other information must appear together on the PDP or the information panel, without intervening material such as unrelated graphics.

The five required elements

1. Statement of identity

The common or usual name of the food, such as "Peanut Butter" or "Sparkling Water". If a standard of identity exists, the name must match it. The statement of identity goes on the PDP, in bold type, generally parallel to the base of the package and in a size reasonably related to the most prominent printed matter.

2. Net quantity of contents

The amount of food in the package, in both metric and US customary units, in the bottom 30% of the PDP. Minimum type sizes depend on the size of the PDP. See our guide to net weight on packaging for the full table.

3. Nutrition Facts

Most packaged foods need a Nutrition Facts label, discussed in detail below.

4. Ingredient list

All ingredients, listed by their common or usual name in descending order of predominance by weight. Ingredients that are themselves made of several ingredients, such as chocolate chips in a cookie, generally need their sub-ingredients listed too. The ingredient list goes on the PDP or the information panel.

5. Name and place of business

The name and address of the manufacturer, packer or distributor. If the company named is not the manufacturer, it must be qualified with phrases such as "Manufactured for" or "Distributed by".

The Nutrition Facts label

The Nutrition Facts label shows nutrition information in a standard format. The FDA updated the label in 2016, with compliance dates that have now passed. The current label includes:

• servings per container and serving size, with serving size in larger, bold type
• calories, in larger, bold type
• total fat, saturated fat and trans fat
• cholesterol and sodium
• total carbohydrate, dietary fiber, total sugars and added sugars
• protein
• vitamin D, calcium, iron and potassium, with actual amounts and % Daily Values
• a footnote explaining % Daily Value

Serving sizes must be based on amounts customarily consumed, set out in FDA reference tables, not on what a brand would like the serving to be.

Formats

The FDA allows several formats depending on package size and product type:

• standard vertical format
• tabular format for packages without enough height
• linear format for small packages
• dual-column formats for packages that could be eaten in one or several sittings, showing "per serving" and "per container"
• simplified formats when many nutrients are zero

Very small packages, with less than 12 square inches available for labelling, may be able to omit nutrition information if they show an address or phone number for consumers to get it.

Exemptions

Some foods and businesses are exempt from Nutrition Facts, such as certain small businesses, foods with no significant nutrition such as plain coffee, and some foods sold in bulk. Some exemptions require notifying the FDA. Do not assume your product is exempt without checking.

Allergen labelling

US law identifies nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Sesame became the ninth major allergen on 1 January 2023.

If a food contains a major food allergen, the label must identify the food source of the allergen in one of two ways:

1. In the ingredient list, in parentheses after the ingredient name, for example "whey (milk)", unless the ingredient name already identifies the allergen.
2. In a "Contains" statement immediately after or next to the ingredient list, for example "Contains: Milk, Wheat, Soy".

For tree nuts, fish and shellfish, the specific type must be named, such as "almonds", "cod" or "shrimp".

Advisory statements such as "May contain" or "Made in a facility that also processes peanuts" are voluntary. They must be truthful and should not be used in place of good manufacturing practice.

Claims

Food labels can carry several kinds of claims, each with rules:

• Nutrient content claims such as "low fat" or "high fiber" have defined criteria.
• Health claims linking a food or nutrient to a reduced risk of disease must be authorised or qualified by the FDA.
• Structure/function claims describe effects on the body's structure or function.
• "Healthy" claims follow a definition the FDA updated in recent years.

Words like "natural" are not formally defined for most foods, but the FDA has a long-standing policy on their use. Claims are a high-risk area, so get them reviewed.

Designing a compliant food label

Plan from the dieline

Calculate the area of the PDP from your dieline, because it determines minimum type sizes for net quantity and affects which Nutrition Facts formats you can use. Identify the information panel early.

Write all the text first

Get the statement of identity, ingredients, allergen statement, nutrition values and claims from your food technologist or adviser before design starts. Lay these out first, then design the brand elements around them.

Do not separate what belongs together

Keep the Nutrition Facts, ingredients and name and place of business together on one panel without unrelated graphics in between.

Proof at actual size

Print the label at 100% and check that the Nutrition Facts panel is legible, the allergen statement is easy to find and nothing important sits on a fold or seam.

Common US food label mistakes

These issues come up again and again when brands bring packaging to us for a redesign:

• Net quantity in the wrong place. Placed at the top of the front panel, or only in metric units.
• Serving size chosen for marketing. Using a smaller serving to make calories or sugar look lower, rather than the FDA reference amount.
• Allergens missing from sub-ingredients. For example, an ingredient such as "natural flavor" or "chocolate" that contains milk or soy without the allergen being declared.
• Sesame not declared. Older labels that predate sesame becoming the ninth major allergen.
• Old Nutrition Facts format. Labels still using the pre-2016 layout, without added sugars or with the old Daily Values.
• Unqualified business name. Naming a brand owner who is not the manufacturer without "Manufactured for" or "Distributed by".
• Interrupting the information panel. Placing graphics, claims or a barcode between the Nutrition Facts and the ingredient list.
• Claims without criteria. Using "low sugar", "high protein" or "healthy" without meeting the definitions.

Imports and other markets

If you are manufacturing outside the US, the same rules apply to the label when the food is sold in the US. Imported food must also show the country of origin under customs rules, and food facilities must be registered with the FDA. Labels for the US are rarely suitable unchanged for the UK or EU, which use different nutrition formats, per 100 g values and allergen lists. If you plan to sell in several markets, design a shared front panel with market-specific back panels, and see our guides to UK labelling and EU food labelling.

How we help

We design food packaging and labels for US and international brands and make printed and rigid boxes in our own factory. We lay out the label text and nutrition data you supply in the right formats and positions and design the brand around it. We do not calculate nutrition values, decide claims or certify compliance; final regulatory review stays with you and your adviser.

See our food packaging design and coffee packaging design services, or get a free quote for your range.

Official sources

• FDA: Food Labeling Guide
• 21 CFR Part 101: Food labeling (eCFR)
• FDA: Changes to the Nutrition Facts label
• FDA: Food allergies

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Questions

What must a US food label include?

A statement of identity, net quantity, Nutrition Facts (unless exempt), an ingredient list with allergen declaration, and the name and place of business of the manufacturer, packer or distributor.

What are the nine major food allergens in the US?

Milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame.

Can small businesses skip Nutrition Facts?

Some small businesses and products qualify for exemptions, often with notification requirements. Check the FDA's rules before relying on one.

Where does Nutrition Facts go?

Usually on the information panel or principal display panel, in the FDA format. Formats vary by package size.