US FDA Nutrition Label Requirements for Small Producers

If you sell packaged food in the US and no exemption applies, you need a Nutrition Facts panel in the FDA format set out in 21 CFR 101.9. Whether you are exempt is covered in the full US requirements guide. This page is the short version of what the panel must get right before you print.

Skip the spreadsheet. Nutrifax is a nutrition label generator that builds a print-ready FDA Nutrition Facts panel from your recipe, rounded per 21 CFR 101.9. Start free →

What it's called

The FDA panel goes by several names, and the spelling splits at the border:

• Nutrition Facts panel is the FDA's own term for the box on the package.
• Nutrition facts label and nutrition label are what most people search for. Same thing.
• Labeling is the US spelling. Canada writes labelling. FDA uses "labeling".

US food labeling requirements, FDA nutrition facts requirements and nutrition label requirements all describe the same body of rules: 21 CFR 101.

Five things the panel must get right

1. Serving size comes from the RACC

The FDA publishes a Reference Amount Customarily Consumed (RACC) for every food category. Your serving size is based on that, declared as a household measure with the metric weight in brackets, for example "1 cookie (30g)". A package holding less than 200% of the RACC is one serving. A package holding 200% to 300% needs a second column for the whole package.

2. Nutrients in the prescribed order

Calories, then Total Fat (Saturated Fat and Trans Fat), Cholesterol, Sodium, Total Carbohydrate (Dietary Fiber, Total Sugars, Added Sugars), Protein, then Vitamin D, Calcium, Iron, and Potassium. Servings per container sits above the serving size. The 2016 format moved Vitamins A and C to voluntary and added Added Sugars and Vitamin D.

3. Rounding per 21 CFR 101.9(c)

Calories under 5 show as 0, up to 50 round to the nearest 5, and above 50 to the nearest 10. Fat rounds to the nearest 0.5 g below 5 g and to the nearest 1 g above. Sodium rounds to the nearest 5 mg up to 140 mg and to the nearest 10 mg above. Carbohydrate, fibre, sugars, and protein round to the nearest gram, with anything under 1 g shown as "less than 1 g" or 0. Rounding by eye produces values that do not match the rule.

4. Percent Daily Value on a 2,000 calorie basis

%DV is required for most nutrients and is calculated from the FDA's Daily Values, which are not the Canadian ones. The footnote wording is prescribed.

5. Claims change everything

Any nutrient content claim ("low fat", "sugar free", "good source of fiber") or health claim on the package, your website, or your ads removes the small business exemption and brings its own conditions for when the claim may be made. Do not put a claim on a label until you have checked the definition for that claim.

Checklist before printing

• final recipe quantities, weighed rather than estimated
• serving size matched to the RACC for your category, in household measure plus grams
• servings per container that matches the package weight
• the panel generated from the final recipe version, not an earlier one
• a test print at 100% on plain paper, checked for minimum type size and the box rule
• the audit report saved with the recipe version, so you can answer "where did this number come from"

Common mistakes

• using values from a similar product instead of calculating your own recipe
• editing the serving size without regenerating the panel
• putting a Canadian Nutrition Facts table on a US product (different order, Daily Values, and rounding)
• printing a screen-resolution image instead of a PDF at the correct dimensions
• adding a "low sodium" or "high protein" flash to the front of the pack without checking that the claim is allowed

What to do in Nutrifax

1. Build the recipe with Ingredient Search, or import it with Paste Recipe or Photo Import.
2. Check each ingredient match and unit. This step decides the quality of the panel.
3. Set servings or yield to match the package.
4. Generate the US format and preview it.
5. Export PDF or PNG and run a test print.
6. Save the audit report with the recipe version (Recipe Pro or Label Pro).

Related pages

• US Nutrition Label Requirements: Who Needs One
• When Nutrition Labels Are Required in the US
• Serving Size and Rounding Rules (US FDA)
• How to Generate and Print Nutrition Labels in Nutrifax
• FDA nutrition label generator

Sources

• FDA: What's on the Nutrition Facts Label
• FDA: Food labeling and nutrition
• FDA: Reference Amounts Customarily Consumed (RACCs)
• FDA: Small business nutrition labeling exemption guidance
• eCFR: 21 CFR 101.9 (Nutrition labeling of food)

Disclaimer

Educational content only; not legal advice. Confirm the final label against current regulations for your product and jurisdiction.