Estimated reading time: 7 minutes
Best for: Packaged-food producers and businesses preparing products for retail or wholesale distribution
What You’ll Learn
- What a Nutrition Facts label communicates
- When nutrition labeling may be required
- What information is needed to create a label
- How recipe accuracy affects nutrition calculations
- Why serving size is important
- What small-business exemptions may apply
What Is a Nutrition Facts Label?
The Nutrition Facts panel is the standardized nutrition information displayed on packaged foods.
It provides consumers with information including serving size, calories, major nutrients, and percent Daily Values.
The current FDA label requires information such as calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, total sugars, added sugars, protein, vitamin D, calcium, iron, and potassium, as applicable under FDA labeling rules.
Nutrition labeling isn’t simply a marketing feature.
For many packaged foods, it is a regulatory requirement.
Start With the Recipe
Before worrying about the appearance of the Nutrition Facts panel, make sure the underlying recipe is correct.
You need:
- Every ingredient
- Exact quantity of each ingredient
- Accurate ingredient nutrition information
- Finished recipe yield
- Serving size
- Number of servings
A nutrition calculation is only as accurate as the recipe information behind it.
If employees make the product differently every week, the label may no longer accurately represent the product.
Serving Size Is Important
Serving size affects every number on the Nutrition Facts panel.
Calories and nutrient quantities are generally presented on a per-serving basis.
Serving sizes aren’t simply whatever amount a manufacturer would prefer customers to consume. FDA serving-size requirements are designed to reflect amounts people customarily consume and include rules for determining the appropriate serving size for a product.
This is one reason producers should determine the proper serving size before finalizing the label.
Two Common Ways to Determine Nutrition Information
Database Analysis
Nutrition information for individual ingredients is entered into nutrition-analysis software.
The software combines:
Ingredient nutrition × ingredient quantity
and divides the resulting totals according to the finished yield and serving size.
This can be efficient and economical, particularly when recipes are well documented.
Laboratory Analysis
A sample of the finished product is sent to a laboratory for analysis.
Laboratory testing can be appropriate when formulation calculations don’t adequately represent the finished product or when more precise testing is needed.
Depending on the product and circumstances, producers may use database analysis, laboratory analysis, or a combination of the two.
The Current Nutrition Facts Label
FDA’s updated Nutrition Facts format includes several changes from the older label.
Among them:
- Calories are displayed more prominently.
- Serving size is emphasized.
- Added Sugars must be declared.
- Vitamin D and potassium are required nutrients.
- Calcium and iron continue to be required.
- Vitamins A and C are no longer universally required.
- Calories from Fat was removed.
Make sure you’re using the current label format rather than copying an old Nutrition Facts panel.
Small-Business Exemptions
Some small food businesses and low-volume products may qualify for an exemption from nutrition-labeling requirements.
One FDA low-volume exemption generally applies when the business has fewer than an average of 100 full-time-equivalent employees and sells fewer than 100,000 units of the product in the United States during a 12-month period. An annual notice to FDA is generally required to claim this particular exemption.
Separate exemptions can apply to businesses with no more than $500,000 in annual gross sales or no more than $50,000 in annual food or dietary-supplement sales to consumers.
But there is an important catch.
Products making nutrient-content claims, health claims, or providing certain nutrition information generally cannot rely on the low-volume small-business exemption.
For example, putting claims such as “sugar free” on a product can change the labeling requirements.
An exemption from Nutrition Facts labeling also doesn’t eliminate other mandatory food-labeling requirements such as ingredient statements and other required product information.
Because labeling requirements depend on the product and how it is marketed, verify the requirements that apply to your particular product before printing thousands of labels.
Ingredients Still Matter
Nutrition Facts are only one part of a food label.
Packaged-food labeling may also involve:
- Statement of identity/product name
- Net quantity
- Ingredient statement
- Allergen declarations
- Manufacturer, packer, or distributor information
- Nutrition Facts
- Required handling or storage instructions
- Other product-specific information
Don’t assume that qualifying for a Nutrition Facts exemption means the product doesn’t need a compliant food label.
Recipe Changes Can Require Label Changes
Suppose you create a Nutrition Facts panel and then six months later:
- Increase the amount of sugar
- Change chocolate suppliers
- Replace butter with another fat
- Increase serving size
- Change the finished product weight
Your existing nutrition information may no longer accurately represent the product.
Nutrition labeling should therefore be connected to recipe control.
Common Mistakes
Guessing serving size. Serving sizes are subject to FDA requirements.
Using incomplete recipes. Small ingredients still contribute nutrients.
Ignoring processing yield. The finished weight of a recipe can affect calculations.
Using old label formats. Make sure the current Nutrition Facts format is being used.
Making claims casually. Terms such as “low fat,” “healthy,” “sugar free,” or other nutritional claims can have regulatory definitions and consequences.
Assuming you’re exempt because you’re small. Exemptions have specific requirements.
Best Practices
Standardize every recipe before creating nutrition information.
Use weight measurements whenever practical.
Maintain accurate ingredient specifications.
Document the finished production yield.
Determine the correct serving size.
Keep a copy of the calculations or laboratory report supporting the Nutrition Facts panel.
Review labels whenever formulations change.
Keep the label version associated with the correct recipe version.
And before committing to a large packaging run, have the entire label reviewed — not just the Nutrition Facts panel.
Software Tips
If your recipes are already maintained electronically, much of the information needed for nutrition analysis already exists.
The same recipe database used for costing can contain:
- Ingredients
- Quantities
- Units of measure
- Recipe yield
- Finished weight
- Serving size
That information can then be exported to nutrition-analysis software or used as the foundation for generating nutrition calculations.
The key is maintaining one accurate recipe rather than separately maintaining a production recipe, costing recipe, and nutrition recipe that eventually become different.
Questions We Hear Every Week
Does every packaged food need a Nutrition Facts label?
No. FDA provides exemptions for certain businesses and products, but the requirements are specific and should be checked carefully.
Can nutrition information be calculated from the recipe?
Often, yes. Ingredient database analysis is commonly used, although some products or circumstances may warrant laboratory analysis.
Can I make my own Nutrition Facts panel?
The underlying information can often be developed using appropriate nutrition-analysis tools, but the final panel still needs to comply with FDA formatting and labeling requirements.
If I’m exempt, can I still put Nutrition Facts on the package?
Voluntarily providing nutrition information can subject the product to applicable nutrition-labeling requirements, so don’t add an informal or incomplete panel simply because customers ask for nutrition information.
What happens if I change my recipe?
Determine whether the change materially affects the nutrition information and whether the label needs to be recalculated.
Related Guides
- Recipe Costing
- Food Safety
- Allergen Management
- Shelf Life
Final Thoughts
Nutrition labeling becomes much easier when the underlying production information is organized.
Start with a standardized recipe, accurate ingredient quantities, finished yield, and correct serving size.
Then determine whether your product requires Nutrition Facts labeling and use the appropriate analysis and label format.
For small producers, getting the recipe and production data organized first can turn what initially looks like a complicated labeling project into a manageable process.