FDA Nutrition Label Requirements

Do you need a Nutrition Facts label?

Not every product does. Many cottage-food makers are exempt and only need an ingredient, allergen, and net-weight label. You generally do need a Nutrition Facts panel when you sell into retail stores, wholesale, or online across state lines, or when you make a nutrient content claim like “low sugar” or “high protein.”

The mandatory nutrients (2016 label)

Since the 2016 update, the panel must declare, in this order:

• Calories
• Total Fat, Saturated Fat, and Trans Fat
• Cholesterol
• Sodium
• Total Carbohydrate, Dietary Fiber, Total Sugars, and Added Sugars
• Protein
• Vitamin D, Calcium, Iron, and Potassium (with amounts and %DV)

Vitamins A and C are now voluntary (they were mandatory before 2016), and “Calories from Fat” was removed.

Serving sizes & RACC

Serving size isn't what you think a serving is. It's based on the FDA's Reference Amounts Customarily Consumed (RACC) in 21 CFR 101.12, stated as a household measure plus grams (for example, “2/3 cup (55g)”). Packages that hold between 200% and 300% of the RACC and could be eaten in one sitting need a dual-column (per serving / per container) panel.

Rounding rules (the tricky part)

The FDA specifies exact rounding for each nutrient. A few examples:

• Calories. Under 5 shows as 0; up to 50 rounds to the nearest 5; above 50 to the nearest 10.
• Fats. Under 0.5g shows as 0; under 5g rounds to the nearest 0.5g; at or above 5g to the nearest 1g.
• Sodium. Under 5mg shows as 0; 5–140mg rounds to the nearest 5mg; above 140mg to the nearest 10mg.
• Carbs, fiber, sugars, protein. Under 0.5g is 0; 0.5–1g shows “less than 1g”; otherwise nearest 1g.

%Daily Values are calculated from the current Daily Values (for example, 78g total fat, 2,300mg sodium, 50g added sugars) and rounded. Vitamins and minerals use 2/5/10% increments; macronutrients round to the nearest whole percent.

Ingredients & allergens (a separate requirement)

Beyond the panel, packaged food needs an ingredient list in descending order of weight and a “Contains” allergen statementfor the FDA's Big 9 (milk, egg, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame). These live near the panel, not inside it.

Common mistakes

• Using a “serving” that doesn't match the RACC.
• Forgetting Added Sugars or Potassium (both mandatory now).
• Rounding to the wrong increment (each nutrient has its own rule).
• Missing an allergen because a sub-ingredient contains it.