Making a food label requires assembling several distinct pieces: a product name, a Nutrition Facts panel, an ingredient list, a net quantity statement, and allergen disclosures. Each piece has specific rules set by the FDA (or the USDA, if your product contains meat or poultry). The process boils down to three phases: gathering your nutrition data, building each required label element, and formatting everything to meet federal standards.
Which Agency Governs Your Product
Most packaged foods fall under FDA jurisdiction, which means you follow FDA labeling rules and self-certify compliance. You do not need pre-approval from the FDA before selling your product. The USDA, however, regulates meat products (including processed meats), poultry products, and egg products like liquid eggs. If your product falls into one of those categories, you must get your label approved by the USDA’s Food Safety and Inspection Service before it goes to market. Everything below covers FDA-regulated products.
Determine If You’re Exempt
Not every small business needs a Nutrition Facts panel. Retailers with annual gross sales of $500,000 or less, or with annual food sales to consumers of $50,000 or less, are exempt from nutrition labeling. A separate exemption covers low-volume products: if your company employs fewer than 100 full-time equivalent employees and sells fewer than 100,000 units of a given product in a 12-month period, that product qualifies. Businesses with fewer than 10 full-time equivalent employees that sell fewer than 10,000 total units annually don’t even need to file an exemption notice.
Even if you’re exempt from the Nutrition Facts panel, you still need a proper ingredient list, allergen disclosures, a net quantity statement, and a product name. And the moment a nutrition claim appears on your packaging (“low fat,” “good source of fiber”), the exemption disappears and a full Nutrition Facts panel becomes mandatory.
Get Your Nutrition Data
You have two main options for figuring out the nutrient content of your product: laboratory testing or nutrient database software. Lab testing involves sending food samples to an accredited analytical lab, which physically measures calories, fat, protein, carbohydrates, and other nutrients. This is the gold standard for accuracy, but it typically costs several hundred dollars per product and takes a few weeks.
Database analysis uses software programs that calculate nutrient values from standardized ingredient data (often drawn from the USDA’s FoodData Central database). Research comparing database calculations to lab results has found no significant difference for calories, protein, or fat. Carbohydrate values showed small but statistically significant differences, and fiber estimates from databases can diverge more meaningfully from lab values. For most products made from common ingredients, database analysis is reliable and far cheaper. If your product uses unusual ingredients, proprietary processes, or if precise accuracy is critical for health claims, lab testing is the safer choice.
Several online tools and software platforms (Nutritionix, ReciPal, MenuCalc) can generate a formatted Nutrition Facts panel once you input your recipe. The FDA also provides downloadable label templates.
The Five Required Label Elements
Statement of Identity (Product Name)
This is the common name of the food, such as “Tomato Sauce” or “Granola Bars.” It must appear on the principal display panel (the part of the package most likely to be seen by the consumer at the time of purchase) in bold type. If the food doesn’t have a well-known common name, use a descriptive name that tells the consumer what the product is.
Net Quantity of Contents
The net weight or volume must sit in the bottom 30 percent of the principal display panel, printed in lines parallel to the base of the container. You need to list both metric units (grams, kilograms, milliliters, or liters) and U.S. customary units (ounces, pounds, or fluid ounces). For a bag of chips, that looks something like “Net Wt 10 oz (283g).” If the principal display panel is 5 square inches or less, the bottom-30-percent placement rule doesn’t apply, though the dual-unit requirement still does.
Ingredient List
List every ingredient by its common or usual name in descending order of predominance by weight. The ingredient present in the greatest amount goes first. For ingredients present at 2 percent or less by weight, you can group them at the end of the list with a phrase like “Contains 2% or less of: salt, citric acid, natural flavor.” Text must be at least 1/16 inch tall, measured by the lowercase letter “o.”
Allergen Declaration
Federal law identifies nine major food allergens: milk, eggs, fish, crustacean shellfish, tree nuts, wheat, peanuts, soybeans, and sesame. If your product contains any of these (or an ingredient derived from them), you must declare it in one of two ways. The most common approach is a “Contains” statement printed immediately after the ingredient list, for example: “Contains: Milk, Wheat, Soy.” This statement must use type at least as large as the ingredient list. Alternatively, you can place the allergen source in parentheses after the relevant ingredient within the list itself, such as “casein (milk).”
Nutrition Facts Panel
This is the most complex element. The current format, updated by the FDA in recent years, requires the following nutrients in order: calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, total sugars, added sugars, protein, vitamin D, calcium, iron, and potassium. Each nutrient (except trans fat, total sugars, and protein in most cases) needs a percent Daily Value.
Added sugars must appear as a sub-line beneath total sugars, reading “Includes Xg Added Sugars,” with both grams and a percent Daily Value. Single-ingredient sugars like honey or maple syrup only need the percent Daily Value for added sugars, not the gram amount.
Setting the Right Serving Size
Serving sizes are not based on what you think people should eat. They’re based on reference amounts that reflect what people actually consume in one sitting, as defined by FDA regulations. These reference amounts were updated to reflect modern eating habits. Ice cream servings went from 1/2 cup to 2/3 cup. Soda servings went from 8 ounces to 12 ounces. Yogurt servings dropped from 8 ounces to 6 ounces.
If your package contains between one and two servings (a 20-ounce soda or a 15-ounce can of soup, for example), you must label the entire package as a single serving. Larger packages that could reasonably be consumed in one or multiple sittings need dual-column labels showing both “per serving” and “per package” values.
Formatting and Typography Rules
The FDA specifies exact typography for the Nutrition Facts panel. The heading “Nutrition Facts” must be the largest type on the panel, larger than 8-point, and it should span the full width of the box. Key nutrients and their percent Daily Values use 8-point Helvetica Black, though the percent sign itself is set in Helvetica Regular. Table labels like “Amount per serving” are 6-point Helvetica Black. Gram values and nutrient subgroups (like saturated fat under total fat) are 8-point Helvetica Regular with 4 points of leading. Vitamin and mineral entries at the bottom use 6-point Helvetica Regular with 1 point of leading.
For small packages with less than 12 square inches of total label surface area, you can use type as small as 6-point, or all uppercase letters at least 1/16 inch tall.
Sizing Your Principal Display Panel
Several label requirements depend on the size of your principal display panel, so you need to calculate it correctly. For a rectangular package, multiply the height by the width of the side that faces the consumer. For cylindrical containers like cans or jars, multiply the height by the circumference, then take 40 percent. For irregular shapes, take 40 percent of the total surface area. In all cases, exclude tops, bottoms, can flanges, and bottle necks from the calculation.
Putting It All Together
Start with your principal display panel: place the product name in bold type and the net quantity statement in the bottom 30 percent. The information panel (typically the surface immediately to the right of the principal display panel) carries the Nutrition Facts panel, the ingredient list directly below or beside it, and the allergen statement. Your business name and address also go on the information panel.
Before printing, compare your label against the FDA’s Food Labeling Guide, which is freely available as a PDF on the FDA’s website and walks through every requirement with examples. If you’re producing a product commercially for the first time, many food business incubators and cooperative extension programs at state universities offer label reviews at low or no cost. Catching a formatting error or a missing allergen disclosure before your labels are printed saves significant time and money.