NC State University



North Carolina State University

College of Agriculture & Life Sciences


In our health-conscious society, consumers are becoming increasingly concerned about the nutritional value of the foods they eat. In response to these concerns, and as a result of consumer confusion about the fat and nutrient content of foods, the federal government now requires many food product labels to contain detailed nutritional information. While this booklet does not cover all of the specifics of the food labeling rules, it will provide some basic explanations about the law's requirements and some sources of information for food processors and producers who may be required to use the labels on their products.

Retail food labels must be truthful and follow federal regulations. The regulations regarding food labels are governed by the provisions of several federal laws, including


This publication is generally intended to assist in labeling those foods regulated by the U.S. Food and Drug Administration (FDA). Meat and poultry products are regulated by the United States Department of Agriculture (USDA) Food Safety and Inspection Service (FSIS). The nutrition information required on the labels of FSIS-regulated products is nearly the same as that for FDA-regulated products. The two agencies have worked together to standardize nutrition labels.

The labeling regulations for foods regulated by the Food and Drug Administration are contained in Title 21 of the Code of Federal Regulations (21CFR),* parts 100-102. The food processor is responsible for the accuracy of product labels and for full compliance with the federal regulations, even if the labels have been furnished to the processor by a distributor. It is a good idea to have all product labels reviewed by the regulatory agency or other knowledgeable person.

*Note: Reference to specific sections of the regulations will be placed in brackets—for example, [101]—and refer to parts of 21 CFR.


Table of Contents


Required Information

Required information must be placed on the principal display panel, an alternate display panel, or on an information panel.

The Principal Display Panel (PDP) is the part of the label most likely to be displayed or examined by the consumer. It must be large enough to accommodate all the mandatory material clearly and without crowding. On a rectangular package this panel is considered to be the size of the largest panel of the box. For a cylindrical package, the height of this panel is the same as the height of the container, excluding the neck, and the width of this panel is 40 percent of the circumference [101.1]. Information required on the principal display panel includes:

The Information Panel (IP) is the part of the label touching the right edge of the principal display panel. Any of the following information not included on the principal display panel must be included on the information panel:


Mandatory Nutrition Labeling

Foods Regulated by the Food and Drug Administration

Mandatory labeling is required for processed foods regulated by the FDA. Meat and poultry products are regulated by the FSIS. However, game meats and seafood packaged at processing plants are included with FDA regulated foods. Nutrition information is to be provided for the product as packaged, but the label may also list nutrition information for products after cooking.

Nutrition information for fresh produce and seafood packaged at the retail level may be voluntarily provided by point-of-purchase materials. Information about raw fruits and vegetables is provided based on the raw product. For seafood, it is based on the cooked product.

Foods Regulated by the Food Safety and Inspection Service

Nutritional labeling is mandatory for processed meat and poultry products except those processed at the retail level or custom slaughtered. Also, meat and poultry products for which nutrient claims are made must be produced under FSIS-approved, in-plant quality control programs to assure compliance with the nutrient values listed on the label. In contrast to FDA-regulated foods, labels for FSIS-regulated products are reviewed and approved before the foods are marketed. The FSIS has designated 45 fresh meat and poultry cuts for retail labeling similar to that allowed on fresh products. These are single-ingredient products, such as fresh or frozen ground beef, chops, and chicken breast.

Both of these agencies will survey for significant participation (FSIS) or substantial compliance (FDA) at the retail level on a two-year cycle. If compliance and participation are found to be inadequate using point-of-purchase information, new regulations will be introduced.

FDA Exemptions for Small Businesses

Certain small businesses are exempt from the requirements for nutrition labeling if they make no nutrition claims for their product or do not put nutrition information on the product's label or in advertising. Nutrition information is not required on the label if the most recent two-year average of business activity shows that the firm has less than $500,000 annual gross sales to consumers or less than $50,000 in food sales to consumers [101.9(j)]. After May 8, 1995, this exemption applies only to persons selling foods directly to consumers. In addition, the FDA provided a phase-in period for foods entering the market before May 8, 1994, based on number of employees and number of units of the food produced. The schedule for exemption is as follows.


To claim the exemption, a firm need only to notify the FDA of the facts supporting the exemption for each product. In the case of firms with fewer than 10 employees and selling fewer than 10,000 units per year, no notification is required. For further information on small business exemptions, refer to publication FSE 94-3, FDA Exemptions for Small Business.

Other exemptions are provided for foods in small packages, foods of no nutritional significance, and foods for immediate consumption. Bulk foods intended for further processing may also be exempt. These exemptions do not apply to foods that are advertised or packaged with nutritional claims or other nutritional information [101.9(j)].

Nutrition Information

Nutrition information must be presented in a standard format. The FDA urges that the information be presented using the graphic specifications in 21CFR Appendix B to part 101 [101.9(d)]. A sample label is illustrated in Figure 1 below. Alternate formats are to be used for special situations. The nutrition label has several parts:


Figure 1. Sample nutrition facts.



The serving or serving size is an amount of food that a person four years of age or older would customarily eat at a meal. It is expressed as a common household measure and its metric equivalent. Reference serving sizes have been established for specific food categories through national surveys. Reference amounts of foods for determination of serving sizes are found in 101.2 for FDA products and 9CFR 317.312 for FSIS products.

The number of servings per container is determined by the serving size. The serving size can be in discrete units such as individual cookies or slices of bread. A package of up to about 200 percent of the reference amount is considered a single serving. The number of servings is usually rounded off to whole numbers, for example, "about 8 servings," or rounded to the half serving when the package contains between 2 and 5 servings [101.9].

Nutrient Content

Provisions are made for mandatory disclosure of the amount of the major nutrients contained: fat, cholesterol, sodium, total carbohydrates, and proteins. Some subcomponents of these categories, for instance, saturated fat, dietary fiber, and sugars, must also be listed. The amounts of vitamins A and C, iron, and calcium must be shown. In addition, the amount of certain other nutrients may be voluntarily disclosed (Table 1). Any claims made regarding a nutrient or one of its subcomponents makes disclosure of the amount of that nutrient mandatory. No other nutrients or food subcomponents may be included in the nutrition label [101.9(c)].


Table 1. Rounding Table for Nutrients


Determining Nutrient Content

The nutrient content of foods for nutrition labeling can be determined either by direct analysis or by determination from a nutrient database. The FSIS approves the use of nutrient data from the USDA Handbook 8 series, which is available from the Superintendent of Documents. The FDA-accepted databases may be used for products regulated by FDA [101.9(g)]. Because manufacturing practices can greatly affect nutrient loss, the manufacturer must assure that the nutrition content data used on the label are accurate.

Food manufacturers should perform analysis of nutrients on a composite of 12 subsamples representative of a particular product or lot. Methods of analysis are contained in the Official Methods of Analysis of the AOAC (Association of Official Agricultural Chemists), or if no AOAC method is available, other appropriate and reliable methods can be used. Usually, those analyses are performed by consulting laboratories. The analysis of a single sample may cost several hundred dollars.

Many manufacturers have taken advantage of commercial databases developed for nutrient data. These databases vary in quality and completeness. Many calculate nutritional data from ingredient formulas. Some allow analysis data from ingredient suppliers to be entered. If these databases are used, manufacturers should be aware of their dependence on the accuracy and completeness of the database and the likelihood of processing-induced changes.

Nutrient Declaration

The label declaration of nutrients should be accurate within 20 percent of the analysis plus a factor for the accepted analytical variability of the method. Nutrient values are to be rounded off in accordance with Table 1. An insignificant amount of the nutrient can be expressed as zero (0). Added nutrients must be present in at least the amounts declared on the label. Compliance is based on the metric measure specified in the serving size. Major nutrients are to be declared by their metric weight and by their percent Daily Value (DV) as established for a 2,000-calorie diet. Vitamins and minerals are declared as a percentage of Reference Daily Intake (RDI) (Table 2).


Table 2. RDI of Vitamins and Minerals



The vertical format shown in Figure 1 is the preferred presentation of the "Nutrition Facts" on the label. For packages with less than 40 square inches available for labeling, the footnote can be abbreviated. For smaller packages or packages with insufficient vertical space and under certain other circumstances other formats are specified [101.9(d)]. The regulation should be consulted for the specific uses of the different formats ([101.9] and 21CFR Appendices A through E of 58 FR 44085-44090, August 18, 1993).

Nutrient Content Claims

Nutrient content claims are statements that describe the amount or range of any nutrient contained in the food or that imply that the food contains a certain amount or range of any nutrient [101.13]. The rules define descriptive terms that can be used to refer to the amount of nutrients present or the absence of nutrients [101 subpart D]. Table 3 below lists defined nutrient descriptors for specific nutrients and the requirements for their use. Other terms are listed in Table 4. If a nutrient content claim is made, the label must contain a referral statement that directs attention to the panel that displays the Nutrition Facts.

In some instances disclosure of negative nutritional information is required on the principal display panel by a statement directing attention to the nutrition information. This statement is required in the following instances


Table 3. Use of Descriptors for Specific Nutrients


Table 3. (continued)


Health Claims

Claims made on the label that express or imply the relationship of any substance to a disease- or health-related condition are considered health claims [101.14]. Only those health claims provided for in 101 subpart E of the regulation may be used. These include the following relationships between nutrients and health conditions:



If levels of certain nutrients are above those listed as follows, the food is disqualified from making a health claim. Those levels are:


Type Size

The sizes and styles of type that can be used for label information are described in the regulation. Generally, the size of the total label area determines the minimum type height that can be used. Required information must be presented in easily readable type. The height of any letter must be no more than three times the width, with the lowercase letter "o" determining the size. Required information must be presented clearly and without crowding.

Other Label Considerations

Label size and required information are dictated by the total area available for labeling on the container. The container choice should be made with the equipment of the packer in mind. Certain containers require specialized equipment to fill and label. Use a label that can be properly applied to the container with the automatic equipment on hand because labeling by hand is tedious and costly. Check the size, style, and quality specifications furnished by the packer. Often, packers use a particular label supplier that is familiar with their requirements. Using these suppliers may prevent future technical difficulties.

Contact the label company representative before designing a label. The supplier's in-house designers may be able to do the design work. It is important to know whether your packer runs cut labels or pressure-sensitive labels. Label orientation and winding must be specified for pressure-sensitive labels. The adhesive must be chosen with product labeling conditions in mind. For both types of labels, product resistance and coating are considerations.

A Word to the Wise

Labeling regulations have undergone considerable change in recent years. Interpretation of the rules is constantly being updated. Consult regulatory personnel, your packer, and your label suppliers before ordering labels. Label plate charges are costly, as is the destruction of inventories of unusable labels, but a marketplace recall can be devastating.

Do everything you can to ensure that your label is correct before printing.


Table 4. Relative Terms for Nutrient Content Claims


Additional Information:

Department of Food Science
North Carolina State University

(919) 5l5-2956

Food and Drug Protection Division
North Carolina Department of Agriculture

(919) 733-3126

Industry Liaison
Food and Drug Administration
(202) 205-5251

Industry Liaison
United States Department of Agriculture
(202) 254-2596


To order copies of regulations 21CFR (FDA) or 9CFR (USDA):

Superintendent of Documents
U.S. Government Printing Office

Washington, D.C. 20402


Universal Product Code (UPC)

Although the UPC symbol is not regulated label information, it is a standard for modern food labels. Proper printing and correct placement of the symbol are important to accurate scanning on automatic inventory and checkout systems.

The symbol is generally placed on the bottom of boxes and on the panel opposite the principal display panel on the food containers. For a single label that does not extend to the rear of the container, the symbol is placed to the left of the principal display panel. To obtain a UPC symbol for your product or for further information on its placement or use contact:

The Uniform Code Council
8163 Old Yankee Road
Dayton, OH 45458


NC State University
North Carolina
Cooperative Extension Service


Prepared by

Patricia A. Curtis, Extension Food Science Specialist

Dwain H. Pilkington, Extension Food Science Specialist

John E. Rushing, Extension Food Science Specialist

Donn R. Ward, Extension Leader, Food Science


Published by



7/94—5M—DWD—240477 AG-503

Distributed in furtherance of the Acts of Congress of May 8 and June 30, 1914. Employment and program opportunities are offered to all people regardless of race, color, national origin, sex, age, or disability. North Carolina State University, North Carolina A&T State University, U.S. Department of Agriculture, and local governments cooperating.

Last modified on April 3, 2000 by Terri Appelboom,
NCSU/CALS Communication Services


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