In FDA regulations, Food labeling
Knowing the difference between mandatory and voluntary nutrients is important for every food manufacturer.

Knowing the difference between mandatory and voluntary nutrients is important for every food manufacturer. Image source: Flickr user Joe Loong.

Gregory was thoroughly confused. He’d finished perfecting the recipe for his protein-packed energy bars, which he’d been selling at the local Farmers Market for the past year. His product was wildly popular, and several customers had asked if they could buy his bars in stores.

Always eager to please his customers, Gregory arranged a meeting with the supplier for a local chain of grocery stores to discuss the possibility of carrying his bars. Prior to the meeting, the supplier asked Gregory to bring a nutrition facts label for his product. Gregory got to work.

As he began researching the elements of the nutrition label, he noticed that some nutrition labels contained more nutrient information than others. Why did one protein bar include vitamin E and magnesium and another one didn’t? And what nutrient information was he expected to list?

While the FDA requires that some specific vitamin, mineral, and macronutrient information be included on nutrition labels, other nutrient information is optional. This was the source of Gregory’s confusion. So, to clarify which nutrients are mandatory and which nutrients are optional on the food label, let’s look at the FDA guidelines for nutrition facts and discuss the value of including optional nutrient information on your label.

What Nutrients are Optional on the Food Label? Mandatory vs. Voluntary Ingredients

As Gregory discovered, understanding the nutrition facts label can be challenging for first-time food manufacturers who are unfamiliar with FDA labeling guidelines. Lengthy documents with complex wording make it difficult to understand exactly what is expected when it comes to the nutrition facts label. So let’s break it down simply, starting with mandatory nutrients, so you feel confident moving forward with your nutrition label.

The following 15 nutrients are mandatory on every nutrition facts panel:

  • Calories
  • Calories from fat
  • Total fat
  • Total carbohydrate
  • Trans fats
  • Cholesterol
  • Sodium
  • Dietary fiber
  • Sugars
  • Protein
  • Vitamin A
  • Vitamin C
  • Calcium
  • Iron

These nutrients are mandatory because the FDA considers them the most essential to either limit our intake of (in the case of cholesterol, sodium, and trans fat) or increase our intake of them (in the case of iron, Vitamin C, and dietary fiber). Since these nutrients are thought to play a more critical role in human health, they are required on the nutrition label.

In addition to the above nutrients, the following nutrients are optional:

  • Vitamin D
  • Vitamin E
  • Thiamin (Vitamin B1)
  • Riboflavin (Vitamin B2)
  • Niacin (Vitamin B6)
  • Folate
  • Vitamin B12
  • Biotin
  • Pantothenic Acid
  • Phosphorus
  • Iodine
  • Magnesium
  • Zinc
  • Copper

If you choose to disclose the values for any of these nutrients on your label, they should be listed after iron on the nutrition facts panel, in the order in which they appear above.  

The only two situations in which information about the above nutrients must be included on your label are:

  • When a specific nutrient is added as a supplement to enrich a food (i.e. Since Gregory added potassium to his energy bar, he must include a value for potassium on his nutrition facts panel)
  • When a nutrient content claim is made on the packaging (i.e. Since Gregory included a “high in vitamin E” nutrient content claim on his package, he must include a value for vitamin E on his nutrition facts panel)

To sum up, FDA rules require that you always include the mandatory nutrients on your label and that you only need to include additional information if you supplement a food with a nutrient or make a claim about a nutrient.

Reasons to Provide Optional Nutrition Information

Of course, you are permitted to include optional nutrients on your food label even if you don’t add them to your product or make a specific claim about them. In fact, food manufacturers do this frequently in order to draw attention to or highlight the diverse nutritional profile of their product.

If your product is a health food item like Gregory’s energy bar, you might want to highlight the nutrients in your product that your target audience would be interested in. For example, if your product is a vegan meat substitute and your nutritional analysis reveals it has a significant amount of Vitamin B12, it would be wise to include it on your nutrition facts label since vegans often struggle to get enough B12 in their diets. This example illustrates why it is so important to know your audience, familiarize yourself with their specific nutritional needs, and attain a complete nutritional profile of your product.

So, how do you get a complete nutrition profile of your product, including optional and mandatory nutrients? Using a FDA-compliant online nutritional analysis software and nutrition facts label generator, like LabelCalc, is the best method. When you enter the recipe for your food product, the software instantly generates a complete nutritional profile and FDA-compliant nutrition facts label. LabelCalc also determines what nutrient content claims (like low-fat) your product qualifies for, so you can easily include additional nutrient information.

In the end, Gregory was not only able to create a FDA-compliant nutrition facts label in time for his meeting, he also included optional nutrient info he thought his target audience would value. In part because he went the extra mile on his label (and in part because his bars are delicious), he impressed the supplier and is now selling his bars in stores, just as he had hoped. So if you are struggling with your nutrition facts label or just want to streamline the label creation process, an easy-to-use online label creation software that clearly denotes optional nutrients makes the task of creating your food label a breeze.

LabelCalc offers FDA-compliant web-based nutritional analysis and label-making that is easy to use, affordable, and informative. To set up an account and create your nutrition facts panel, contact us today.

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