Even if your business is exempt from the Nutrition Facts panel, these elements are still required. The small-business labeling guide covers who qualifies for that exemption — it removes only the panel, nothing here.
The required label elements
Under 21 CFR Part 101, a packaged food label must carry the statement of identity, the net quantity of contents, the Nutrition Facts panel, the ingredient list, and allergen information, plus the name and address of the manufacturer, packer, or distributor. This guide covers identity, net quantity, and the ingredient list; the panel has its own guide, and allergens have theirs.
Statement of identity
The statement of identity is the common or usual name of the food — what it actually is. Per 21 CFR 101.3, it must appear on the principal display panel (the part a shopper sees first), in bold type, generally parallel to the base of the package, and prominent — at least half the height of the largest print on the label. A brand name alone is not enough: 'Grandma's Best' does not identify the food; 'Chocolate Chip Cookies' does.
Net quantity of contents
The net quantity of contents states how much food is in the package by weight, volume, or count. Under 21 CFR 101.7 and the Fair Packaging and Labeling Act, it sits in the bottom 30% of the principal display panel, parallel to the base, and is generally shown in both US customary and metric units — for example, 'Net Wt 12 oz (340 g).' Random-weight and retail-packed items have some flexibility on the metric portion.
The ingredient list
The ingredient list follows 21 CFR 101.4. The core rules:
- Descending order by weight — list ingredients from most to least, measured by their weight at the time they are added during manufacturing, not after cooking drives off moisture.
- Common or usual names — use the recognized name, not a supplier's trade name; the source of fats and oils must be specified ('soybean oil,' not 'vegetable oil').
- Sub-ingredients — a compound ingredient must either be followed by its components in parentheses (e.g., 'chocolate chips (sugar, chocolate, cocoa butter)') or have all its components broken out into the main list.
- The 2%-or-less rule — ingredients present at 2% or less by weight may be grouped at the end, in any order, after a statement such as 'Contains 2% or less of:'.
- Certified colors by name — color additives subject to certification must be named specifically ('FD&C Yellow No. 5'), while spices and natural flavors may generally be grouped as 'spices' or 'natural flavor' (artificial flavors must be identified as artificial).
The single most common cause of food recalls is an allergen hiding in a sub-ingredient that was not carried through to the label. Whenever you list a compound ingredient, check every component against the nine major allergens.
Putting the label together
With the identity, net quantity, ingredient list, and allergen statement in place, add your business name and address and — unless you qualify for the exemption — the Nutrition Facts panel. Generate the panel from your recipe with the Nutrition Facts label generator, after calculating the per-serving numbers with the recipe nutrition calculator.