Register first, then design
Under the Home-to-Market Act, which reshaped this area from 1 January 2022, you register with your county health department and receive a certificate of registration. The fee is capped by law at $50.
Do this before you design the label, not after, because the registration produces a number that has to appear on it.
The label, field by field
Illinois asks for more separate pieces of information than most states. In order:
1. The required statement. In prominent lettering:
This product was produced in a home kitchen not inspected by a health department that may also process common food allergens.
Read that to the end. The Illinois statement carries an allergen cross-contact warning inside the disclosure itself. Most states make you disclose the uninspected kitchen and handle allergen cross-contact separately, if at all. Illinois folds them together, and the sentence is not complete without the second half.
2. The name of the cottage food operation.
3. The unit of local government where the operation is located. County, township, city, or village. Few states ask for this, so it is the field most often missing when a template is adapted from elsewhere.
4. Your identifying registration number, from the certificate above.
5. The date the product was processed or prepared. Most cottage food regimes ask for a production date only on refrigerated goods, if at all. Illinois wants it as standard, and that has a consequence: your labels cannot be fully pre-printed. Either leave a field to complete per batch, or print per batch.
6. The ingredients, in descending order by weight.
7. Allergen labelling as specified under the federal requirements, covering all nine major allergens including sesame.
What the date field does to your workflow
A pre-printed roll of labels, which is the standard economical approach elsewhere, does not work in Illinois without modification. Three practical routes:
- Pre-print everything except the date, leave a blank, and fill it in with permanent ink per batch
- Print labels per batch, which suits short runs and variable products
- Use a separate date sticker applied at packing
Whichever you choose, decide it before you order a large quantity of pre-printed stock. A thousand labels with no room for a date is an expensive lesson.
Sales channels and scope
The Home-to-Market Act allows certain home-kitchen foods to be sold directly to consumers with limited regulation. The scope is direct-to-consumer; it is not a route into wholesale or retail distribution. If a shop wants to stock you, that is a different regulatory conversation, and typically a different kind of licence.
The Nutrition Facts panel
Illinois does not require one. That question is federal, and most cottage food operations are exempt under 21 CFR 101.9(j)(1): annual gross sales of $500,000 or less, or annual gross sales of food to consumers of $50,000 or less, with nothing to file.
The exemption ends if you make a nutrient content or health claim on the label, in labeling, or in advertising, or if you pass those thresholds.
Illinois has its own version of the claim trap. Because the required statement already mentions allergens, producers start to treat the label as the place where health information goes, and add more of it: a gluten free flag, a sugar content note, a "contains no nuts" reassurance. The allergen disclosure Illinois mandates is not a nutrient content claim and does not affect your exemption. Some of what you add next to it will be.
Worth separating two things that get confused. "Low sugar" is a nutrient content claim and ends the exemption. "Gluten free" is a different animal: it is defined at 21 CFR 101.91, which sits in the part of the regulations covering descriptive claims that are neither nutrient content claims nor health claims. So do not assume a gluten free flag costs you the panel exemption. Do note that it carries its own obligations, because the food has to actually meet the federal gluten-free standard, and that is a testing question rather than a labelling one.
Building the panel
Nutrifax generates the Nutrition Facts panel in the FDA 2016 format, rounded per 21 CFR 101.9, from your recipe and the USDA FoodData Central composition data underneath it. Build or import the recipe, check the ingredient matches, set the serving size from the reference amount for your category, and export a print-ready PDF or PNG.
Given the date-per-batch constraint, keep the panel and your fixed fields in one printed block and put the date somewhere it can be written in or overprinted.
Related pages
- Cottage Food Label Requirements by State
- When Nutrition Labels Are Required in the US
- US FDA Nutrition Label Requirements for Small Producers
- Serving Size and Rounding Rules (US FDA)
- FDA nutrition label generator
Sources
- Illinois Department of Public Health: Cottage food
- University of Illinois Extension: Cottage food labeling and placards
- FDA: Small business nutrition labeling exemption guide
- eCFR: 21 CFR 101.9 (Nutrition labeling of food)
Disclaimer
Educational content only; not legal advice. Registration is handled by county health departments and local practice varies. Confirm current requirements with the Illinois Department of Public Health or your county health department, and confirm the final label against current regulations for your product and jurisdiction.