Do I Need Nutrition Facts on My Product? A New Food Manufacturer’s Guide to Labeling
Kathryn was crazy about cheesecake. For as long as she could remember, she’d been baking them with her mother for every birthday and holiday. As she got older, she began tweaking her mother’s recipe and experimenting with different flavors. Soon, her friends started requesting her decadent desserts for special occasions, and before she knew it, Kathryn was making money selling her signature cakes.
“You’ve got to get these into stores,” her friends told her. The problem was, Kathryn had no idea where to begin. Sure, she could bake a mean chocolate truffle cheesecake, but she didn’t know the first thing about selling a product in stores. How would she go about it? Did she need a nutrition label? If so, how would she make one?
From my years of experience working with new food manufacturers, I’ve come to understand that the thought of making a nutrition label for a product can be daunting. While not all food manufacturers are required to provide a nutrition label, there are definite benefits to doing so anyway. Whether you’re an avid cheesecake baker or a serious sausage maker, I’ll help you determine whether you need nutrition facts on your product and discuss the benefits of voluntarily providing them.
Do I Need Nutrition Facts for My Product?
Whether you’re just starting to toy with the idea of selling your product in stores or you already have a retail location interested, you’re going to want to know if your product requires a nutrition facts label. It isn’t mandatory for every single food product to have a nutrition label—but it really depends on what the product is and where it is being sold.
Luckily, the FDA provides detailed guidance for cases in which your product is exempt from nutrition labeling, including:
- You sell your product exclusively through small business retailers with less than $500,000 of annual gross sales and less than $50,000 annual food sales. This means you are free to sell your product in small retail stores that fit within this category without labeling, but larger stores and chains will require a nutrition label.
- Your product is considered “low-volume,” meaning less than 100,000 units are sold in a 12 month period within the United States AND you have less than 10 full-time employees. If this is you, you must file an exemption notice with the FDA each year (unless you sell less than 10,000 units annually).
- It isn’t a significant source of nutrients, like coffee, tea, spices, and vanilla or other extracts.
- Your product is packaged, single-ingredient fish or game that has been custom-processed.
- Your product is single-ingredient raw fruit or vegetables.
- Your product is a baked good that is prepared and sold onsite (i.e. in a cafe).
The only case in which you would still need a nutrition facts label within these categories is if your product made any nutrient content claims like low-fat or low-calorie on its signage or packaging. If you choose to make such claims about your product, you must include a nutrition facts panel to substantiate them.
The Benefits of Voluntarily Providing a Nutrition Facts Panel
When she first started selling her cheesecakes in a small corner store, Kathryn was exempt from having to provide a nutrition facts panel on her product. She did, however, decide to voluntarily make one anyway so her customers had as much information as possible about her product.
While not having to provide a nutrition facts panel can certainly save you some money, especially when you are just starting out, there are many benefits to voluntarily providing a nutrition facts panel on your product label despite being exempt. In many cases, the small upfront investment pays off.
Here are a few reasons why providing nutrition facts on your exempt product is a wise business choice:
- Transparency: It’s no secret that consumers want to know what is in their food, and that includes its nutrients. A recent consumer report found that 94% of respondents said that transparency and honesty are important to them when choosing a brand and a product. Therefore, if your product doesn’t have nutrition information, it could negatively impact sales.
- Professionalism: Americans are used to seeing nutrition facts panels on their food products and have come to expect it. A product without nutrition information may appear less professional or legitimate compared to one with complete nutrition facts.
- Scaling up: You never know just how quickly your product will catch on. The world of food manufacturing can be unpredictable, so it is a good idea to be prepared for anything. Sometimes, all it takes is a few customer requests to see your product carried in a local grocery store chain, and suddenly you need a nutrition facts panel. It is better to be ready for the expansion of your product. This way, you aren’t scrambling to make a nutrition facts label so you can get your product on major retail shelves.
- Customer requests: It’s been my experience that manufacturers who are exempt from nutrition labeling and don’t provide nutrition facts on their product tend to get a lot of customer requests to do so—or at least to provide nutrition info via email or on a website. Save yourself the time and energy you would spend responding to these requests by providing nutrition facts from the start.
- Marketing: If your product is super healthy or has certain nutritional qualities you feel would appeal to consumers, highlight them! Nutrient content claims (like low-fat) can be a major selling point, but as I explained above, you can’t make any claims unless you provide a nutrition facts panel. Using nutrient content claims and nutrition facts can help market your product to its fullest potential.
I always recommend that new food manufacturers provide nutrition facts labels because the above reasons outweigh the costs of making a label. In fact, cost doesn’t have to be a hindrance at all. With FDA-compliant online nutrition analysis software such as LabelCalc, making a nutrition facts label can be quite affordable.. Such software is much more affordable than using food lab analysis, personal consultants, or CD-ROM programs.
There’s no telling just how big your food company will become. Kathryn, the cheesecake queen, went from selling her cheesecakes in a tiny corner store to being a top seller in a major retail chain in only a few months. While she had a lot to figure out during that transition—from hiring employees to finding a new commercial baking space—she had one less thing to worry about because she’d already made her nutrition label. You may not need nutrition facts on your product now, but choosing best practices early on can make all the difference for your business down the road.