US Nutrition Label Requirements: A Guide for Cottage Food Producers and Small Food Businesses

Learn when FDA nutrition labels are required for small food businesses, who qualifies for the small business exemption, cottage food rules by state, and how to generate compliant labels without a lab.

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Quick answer

  • Many small food businesses in the US are exempt from nutrition labeling. If your business has less than $1 million in annual food sales and fewer than 100 full-time equivalent employees, you likely qualify for the federal small business exemption.
  • Cottage food laws are state-by-state. The FDA sets the label format rules, but whether you need a label at all as a home-based producer depends on your state. Some states require nutrition labels on cottage foods, most do not.
  • If you make a nutrient content claim or health claim (e.g. "low fat," "heart healthy") on your label or in advertising, you lose the small business exemption and must display a Nutrition Facts panel.
  • If you do need a label, it must follow the FDA format. The US Nutrition Facts panel is a different document from the Canadian Nutrition Facts table. Using the wrong country's format is a compliance failure.

Do I need a nutrition label?

  1. Are you selling a packaged food product? If no, stop. Unpackaged foods sold directly to consumers (like a slice of pie at a bake sale) generally do not need a Nutrition Facts panel.
  2. Does the federal small business exemption apply? If your business has under $1 million in annual food sales AND fewer than 100 full-time equivalent employees, you are likely exempt at the federal level. But read the exemptions section below for the full conditions.
  3. Are you a cottage food producer selling under your state's cottage food law? If yes, check your state's specific rules. Most states do not require nutrition labels on cottage foods, but some do.
  4. Do you make any nutrient content or health claims? If yes, you need a Nutrition Facts panel regardless of other exemptions. This includes claims like "sugar free," "good source of fiber," or "may reduce risk of heart disease."
  5. If none of the above exemptions apply, you need a label.

Not sure where you fall? Read the full breakdown below.

Who needs a nutrition facts panel in the US

The FDA requires a Nutrition Facts panel on most packaged foods sold in the United States. The rules come from federal regulations, primarily under Title 21 of the Code of Federal Regulations. But unlike Canada, the US has a meaningful small business exemption that covers a large number of producers.

The federal small business exemption

This is the most relevant exemption for the target audience of this guide. You qualify if your business meets both of these conditions:

  • Annual food sales of less than $1 million (total gross sales of food to consumers), AND
  • Fewer than 100 full-time equivalent employees

If you qualify, you are not required to put a Nutrition Facts panel on your products. However, you must file a notice with the FDA claiming the exemption. The filing is straightforward and can be done through the FDA's online portal. If you do not file, you are technically not exempt even if you meet the thresholds.

There is an important catch: if you make any nutrient content claim (like "low sodium" or "high protein") or any health claim on your label or in advertising, you lose the exemption immediately. You cannot claim your granola is "high fiber" and also claim the small business exemption. If you make the claim, you need the panel.

Cottage food laws (state by state)

Cottage food laws allow home-based producers to sell certain foods without a commercial kitchen license. These laws are set by individual states, not the FDA. They vary widely.

Most state cottage food laws do not require a Nutrition Facts panel. Many require only basic labeling: product name, ingredients list, allergen warnings, producer name and address, and a statement that the product was made in a home kitchen. But a handful of states have additional requirements, and the rules change regularly.

The FDA does not override state cottage food laws. If your state says you need a nutrition label, you need one. If your state does not require one, and you meet the federal exemption criteria, you are generally in the clear.

Check your state's department of agriculture or health department website for current cottage food rules.

Other federal exemptions

Beyond the small business exemption, the FDA exempts certain product categories from nutrition labeling:

  • Foods served in restaurants, cafeterias, and similar establishments (though chain restaurants with 20+ locations have separate menu labeling rules)
  • Foods sold by small retail establishments that also prepare the food on-site (e.g. a bakery selling its own bread)
  • Plain coffee and tea
  • Some spices and flavorings with no significant nutritional content
  • Raw fruits, vegetables, and fish (these are covered by voluntary point-of-purchase nutrition information instead)
  • Infant formula (which has its own separate labeling requirements)
  • Medical foods

What happens if you should have a label and don't

The FDA can issue warning letters, require corrective action, and in serious cases pursue seizure of products or injunctions. For most small producers, the first step is a warning letter requesting that you come into compliance. State agencies may also enforce labeling rules independently. Correcting a label after the fact is not difficult, but receiving a warning letter can complicate relationships with retailers and distributors.

Need a label? Nutrifax generates FDA-compliant Nutrition Facts panels from your recipe in minutes. Start free →

How to generate your label

Generating a compliant label in Nutrifax takes about 10 minutes if you have your recipe and ingredient weights ready.

Nutrifax calculates nutrition primarily from USDA FoodData Central, the same database maintained by the US Department of Agriculture. The system also draws from Health Canada's Canadian Nutrient File where USDA data is thin, giving broader ingredient coverage. Recipes are broken down by ingredient and measure, and nutrients are summed per serving using reference data. The system applies FDA rounding rules and outputs a Nutrition Facts panel in the standard US format. An audit report documents the full calculation path (ingredient, measure, data source, and nutrient contribution) for traceability and compliance review.

What the label must include

If you determine that you need a Nutrition Facts panel, it must follow the FDA's prescribed format. The current format (updated in 2016, with compliance deadlines that have since passed) includes some changes from the older version, including updated daily values, a separate line for added sugars, and adjusted serving sizes.

Core nutrients

The Nutrition Facts panel must declare, in this order:

  • Serving size (in both household and metric measures)
  • Servings per container
  • Calories
  • Total Fat (with Saturated Fat and Trans Fat as sub-items)
  • Cholesterol
  • Sodium
  • Total Carbohydrate (with Dietary Fiber, Total Sugars, and Added Sugars as sub-items)
  • Protein
  • Vitamin D
  • Calcium
  • Iron
  • Potassium

Other vitamins and minerals may be declared voluntarily. Percent Daily Value (%DV) must be shown for most nutrients, based on a 2,000-calorie daily diet. The daily values used are US-specific and differ from Canadian values.

Serving size rules

Serving sizes are based on Reference Amounts Customarily Consumed (RACCs), which the FDA publishes for each food category. The serving size on your label must reflect the RACC for your product type, not an arbitrary portion you choose.

For products sold as a single serving, the entire package is the serving size if the contents are between 100% and 200% of the RACC. For products between 200% and 300% of the RACC, you may label them as either one or two servings. Serving sizes must be expressed in both a household measure (cups, tablespoons, pieces) and the metric equivalent in grams or milliliters.

Format requirements

The Nutrition Facts panel must use Helvetica or Arial as the typeface. The heading "Nutrition Facts" must be the largest type in the panel. Specific rules govern line weights, spacing, and minimum type sizes. The panel must be enclosed in a box with a hairline rule border. For very small packages (less than 40 square inches of available label space), a simplified or tabular format may be used. Refer to FDA guidance documents for exact formatting specifications.

Common mistakes small producers make

Using the wrong country's label format

The US Nutrition Facts panel and the Canadian Nutrition Facts table are different documents with different layouts, nutrient orders, daily values, and rounding rules. If you sell in the US, use the FDA format. If you sell in both countries, you need separate labels for each market. This is one of the most common mistakes for producers near the border or selling online.

Wrong serving size

Using an arbitrary serving size instead of the FDA's RACC for your product category is a compliance failure. "1 cookie" is not a valid serving size just because you sell cookies. You need to look up the RACC for cookies (which is 30g) and base your serving declaration on that. If your cookie weighs 55g, the entire cookie is one serving (since it falls between 100% and 200% of the RACC).

Losing the exemption by making claims

This catches more producers than you might expect. Putting "sugar free" or "good source of protein" on your label or website means you now need a full Nutrition Facts panel, even if you otherwise qualify for the small business exemption. The trigger is any nutrient content claim or health claim, whether it appears on the package, on your website, or in advertising materials.

Rounding errors

FDA rounding rules are specific. Calories are rounded to the nearest 10 (below 50 cal, to the nearest 5). Fat, carbohydrate, and protein have their own rounding increments. Using round numbers that "look right" instead of following the prescribed rounding tables will produce non-compliant values. Canadian rounding rules are different, so values from a Canadian label cannot be copied onto a US label.

Not filing the small business exemption

Qualifying for the exemption is not enough. You must actually file a notice with the FDA. Without the filing, you are not technically exempt, even if you meet both the revenue and employee thresholds. The filing can be done online and is not complicated, but many producers skip it because they do not know it is required.

Sources and reference links

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