It’s no secret to those in the food manufacturing industry that the FDA is pretty particular—especially when it comes to nutrition facts labels. Of course, they have the public’s best interests at heart, but making sure nutrition labels are compliant down to the last detail can be challenging for food manufacturers.

One of the most frustrating parts of the label creation process for those who are just starting out in the industry is understanding the nutrition facts label size requirements. From specific font sizes to label size and formatting guidelines, there is a lot to consider when it comes to your nutrition facts panel.

To make things simpler, let’s examine some of the FDA’s most important rules regarding font and label size/format, and explore an easy way of creating the perfect FDA-compliant nutrition label.

What Needs To Be Listed on a Nutrition Facts Label?

• Serving Size and Servings Per Container
  • Clearly listed at the top of the Nutrition Facts Panel
  • Reflects the typical amount consumed in one sitting
• Calories Per Serving
  • Displayed prominently
  • Includes calories per container if there are 2-3 servings
• Mandatory Nutrient Details
  • Total Fat
  • Saturated Fat
  • Trans Fat
  • Cholesterol
  • Sodium
  • Total Carbohydrates: Includes Fiber, Total Sugars, and Added Sugars.
  • Protein
  • Vitamin D
  • Calcium
  • Iron
  • Potassium
• Nutrient Amounts and Daily Values
  • Actual value of each nutrient.
  • Percentage of daily recommended value (%DV) provided by a serving (except for trans fat, total sugars, and protein, though %DV for protein can be shown if the quality of the protein is qualified.
• Voluntary Nutrient Information
  • Information on optional nutrients like sugar alcohols, unsaturated fats, and other vitamins and minerals (e.g., Vitamin C, Vitamin A, Magnesium, Zinc) can be included. FDA allows voluntary declaration of 35 additional nutrients.  The nutrient must be on this list, or it cannot appear on the label. To view the list of current regulations, visit: https://www.ecfr.gov/current/title-21/part-101/section-101.9#p-101.9(c)

• Special Note
  • Optional nutrients may become mandatory if specific claims about them are made.

When Do You Need to Use a Nutrition Fact Label?

Understanding when you are required to include a Nutrition Facts label on your products is crucial for compliance with FDA regulations and ensuring consumer transparency. Here are some key scenarios where a Nutrition Facts label is mandatory:

• Retail Sale
  • If your product is intended for sale in retail stores, a Nutrition Facts label is typically required. This ensures that consumers have access to important nutritional information at the point of purchase.
• Food Service
  • If you supply pre-packaged food to restaurants, cafeterias, or other food service establishments, a Nutrition Facts label is often required. This helps these establishments provide accurate nutritional information to their customers.
• Mail Order Items
  • Products that are ordered on line and delivered directly to the consumer must be labeled the same way as retail food.
• Health Claims
  • If your product packaging makes any health claims (e.g., “low fat,” “high in fiber,” “heart-healthy”), you must include a Nutrition Facts label. These claims trigger the need for full disclosure of the nutritional content to validate the claims being made.
• Nutrient Content Claims
  • Similar to health claims, if you make specific nutrient content claims (e.g., “20% of your daily calcium,” “50% less sugar”), a Nutrition Facts label is necessary. This provides consumers with the context needed to understand the significance of these claims.
• Special Dietary Uses
  • Products designed for special dietary uses (e.g., gluten-free, diabetic-friendly) need to include a Nutrition Facts label to ensure that consumers with specific dietary needs have the necessary information.

When Are You Not Required to Use a Nutrition Fact Label?

While most products are required to have a Nutrition Facts label, certain foods and situations are exempt. Here are the key exemptions:

• Raw Fruits, Vegetables, and Fish
  • These whole, unprocessed foods are naturally exempt from labeling requirements.
• Foods That Do Not Contain Any Significant Nutrients
  • Foods containing insignificant amounts of all required nutrients, such as tea, coffee, and food coloring, can be exempt. Insignificant amounts mean the nutrients can be listed as zero after rounding rules are applied.
• Food prepared and sold on site only (not sold in any other location)
• Food Sold From Bulk Containers
• Bulk food intended for further processing (Business to Business)
• Small Packages
  • Packages with a total surface area available for labeling of less than 12 square inches are exempt.
• Small Retailers
  • Retailers with less than $50,000 in food sales (regardless of total sales) or less than $500,000 in total sales (regardless of food sales) are exempt.
• Low Volume Food Products
  • To claim this exemption, you must employ fewer than 100 full-time equivalent employees (FTEs) and sell fewer than 100,000 units of the product per year. This exemption must be filed with the FDA unless you employ fewer than 10 FTEs and have annual sales of fewer than 10,000 units. Note that many customers will not honor this FDA exemption and will require products to labeled regardless of low volume.

Important Considerations

• Loss of Exemption: Any exemption is forfeited if you make a nutrient content claim or health claim on your product label.

How Have Nutrition Label Laws Changed?

The nutrition information panel was established in 1990 with the passage of the Nutrition Labeling and Education Act (NLEA). The NLEA aimed to create an easy-to-understand and adaptable format for nutrition facts information, one that could evolve with our growing knowledge of nutrition. Despite its forward-thinking goals, the panel saw no significant changes until a major overhaul in 2016. These updates, the first in 25 years, became mandatory for all FDA-regulated manufacturers on January 1, 2021.

The FDA updated the Nutrition Facts label on packaged foods to reflect the most current scientific information and dietary guidelines. Key changes included larger and bolded calorie counts, updated serving sizes, and the addition of “Added Sugars” in grams and as a percentage of daily value. The label now also requires Vitamin D and potassium, while Vitamins A and C are no longer mandatory but can be listed voluntarily. These updates aim to help consumers make more informed food choices and better understand their nutritional intake.

The updated label includes several important changes.

• Emphasized Calories:
  • The layout was changed to make the calorie count more prominent
• Dual Column Format:
  • A new format for packages with 2 to 3 servings, showing nutrition information per serving and per package
• Updated Vitamins and Minerals:
  • Changes in the required vitamins and minerals to address current nutrient deficiencies
  • Introduction of Vitamin D and Potassium as mandatory listings, replacing Vitamins A and C
• Revised Recommended Daily Intake:
  • Updates to the recommended daily intake for several nutrients, affecting their % Daily Value (%DV)
• Redefinition of Fiber:
  • Updated definition of dietary fiber to include only fibers with proven health benefits
• Added Sugars:
  • A new line for added sugars to help consumers manage their sugar intake
• Serving Size Adjustments:
  • Revised reference amounts for serving sizes to reflect actual consumption patterns, impacting categories such as ice cream and yogurt

Nutrition Facts Label Size Requirements and Font Standards

Whether you’re just starting in the food manufacturing business or you have been in the game awhile, understanding FDA food labeling isn’t easy or intuitive. Sifting through the lengthy documents outlining nutrition facts label size and format requirements can be time-consuming, overwhelming, and somewhat confusing, so let’s break it down. Basically, when it comes to nutrition label size, there are two main things to consider: font size and label size/formatting.

Font Size Guidelines: Any label that does not meet the following font size requirements will be seen as “misleading” by the FDA, so it is important to adhere to these. Condensing a label is allowed, but be aware that the minimum font size requirements still apply. Here are some of the common guidelines every food manufacturer should be aware of:

• “Nutrition Facts” lettering must be bigger than any other font on the nutrition label (except for the numerical value for calories) and must span the length of the whole nutrition facts panel.
• The smallest font sizes that can be used on the nutrition facts label are 6 point (for the lettering below vitamins, minerals, and footnotes) and 8 point (for the rest of the label).   
• “Calories” lettering must have a font size of at least 16 point (or 10 point for small packages).

Label Size/Format Guidelines: Adhering to the minimum font size guidelines will ensure the nutrition label is large enough to be legible. The size of your packaging will help determine where your label must go and what format is most appropriate. Here are some basic guidelines for label placement and format based on the size of your packaging:

• For packages with more than 40 square inches of total surface area, the nutrition label must appear on the information panel (IP), principal display panel (PDP), or somewhere within plain sight of the consumer. The Standard Vertical format should be used unless there is a valid reason why it cannot.
• If the package has insufficient vertical space for the standard nutrition labeling, you must use the tabular nutrition label format or the standard vertical side-by-side format.
• For packages with a total surface area of 40 square inches or less, the nutrition label can go on any part of the package. Depending on the packaging, you may qualify for tabular/small or linear label formats.

In addition to the formats mentioned above, LabelCalc has other formats you may want to consider for your product. Remember, what you choose should depend on what is most legible for your particular packaging. You must be able to justify the use of smaller formats for reasons other than marketing materials.

About LabelCalc

LabelCalc, a Datacor company, is used by food manufacturers worldwide to generate accurate nutrition facts labels quickly and easily. Within just a few mouse clicks, the intuitive and user-friendly software compiles relevant information about ingredients, nutrition information, serving sizes, and allergens – all correctly formatted and compliant with the latest FDA rules. Not only is it proven to save a lot of time, but there’s also no need to worry about any calculations or math behind the scenes – LabelCalc does all the hard work for you!

If you have any questions about our trusted software solution, email Tracy Herb, Product Owner – LabelCalc, at tlherb@datacor.com. To get a quote or request a demo, visit https://labelcalc.com/contact-us/.