My Food Product: Do I Need Nutrition Facts On My Labels?
When you have a food business the question of nutrition fact labels will eventually arise. It may be a customer requesting them, a store that is considering carrying your product, or even yourself.
Naturally, you should ask yourself if you NEED nutrition labels on your packaging. This is actually a two part question, because on the one hand the FDA has certain rules for when you are required or exempt from having nutrition facts on your label. On the other hand, you are always permitted to voluntarily include nutrition facts in your packaging - whether it be for personal reasons, marketing, or customer requests.
In short, nobody is going to stop you from adding a nutritional panel to your product's packaging, but in this post we'll go over the FDA rules for when you are obligated to do so.
When You Need Nutrition Facts
If you'd like to investigate the rules yourself, take a look at the FDA guide on exemptions to nutrition fact labeling. Below is a list of situations for which you are required to have nutrition facts:
- First of all, foods that have any nutrient claims (e.g. "Gluten free", "Low fat", etc.). This is the number one rule that requires nutrition fact labeling. If any exemptions are met, your food still has to include nutrition facts if the label has any nutrient claims.
- Small businesses (your own or any that sell your product) that have more than $50,000 of food sales AND more than $500,000 of total sales. So, if you want to be in any major grocery chain, you'll need nutrition fact labels.
- Small businesses with more than 10 full-time equivalent employees or sales of more than 100,000 units.
On the flip side, the following is a list of situations for which you are exempt from having nutrition facts:
- Raw fruits, vegetables, and fish are exempt from nutrition fact labeling.
- Foods that contain insignificant amounts (insignificant means it can be listed as zero) of all required nutrients (foods that fall under this exemption include tea, coffee, food coloring, etc.).
- Foods with total packaging surface area available for labeling of less than 12 square inches.
- Small businesses are exempt if they have either less than $50,000 of food sales (and any amount of total sales) or less than $500,000 of total sales (and any amount of food sales).
- Low volume food products: the person claiming the exemption employs fewer than 100 FTEs and sells fewer than 100,000 units of the product per year. This exemption must be filed in paper to the FDA unless you employ fewer than 10 FTEs and annual sales of fewer than 10,000 units. Once you break the 100,000 unit or 100 FTE threshold you then have 18 months to start labeling your foods with nutrition facts.
Beyond The Rules
Most food companies start providing nutrition facts on their labels well before they hit any of these thresholds because it's good practice, provides a layer of transparency for your customers, and just seems like the right thing to do. But if you don't yet provide them yet, keep these rules in mind. And when the time comes, we're here to make it easier for you to get started making nutrition fact labels.
If you have any questions, don't hesitate to email us, as we're happy to entertain any and all questions. We usually provide good answers too!