What do I need to know about LABELING my foods for sale?

What is a food label?

Food labels are used to easily identify your product. Labeling is important because it provides your customer with detailed information, including ingredients, nutrition facts, and other details about your food and your company. It is also a way to brand and advertise your product.

Why do I need a food label?

The Food and Drug Administration (as well as state regulations) require labeling of all foods packaged for retail sale.

What are the parts of a food label?

The label on your package can be divided into two different portions sections, 1) the primary display panel and 2) the information panel.

1) Primary Display Panel (PDP)

The Primary Display Panel is the section of the package most visible to the consumer. It is usually the portion on the front of the package that faces the customer on the retail shelf. By regulation, the PDP must contain:

1. Product name (identity statement): This is the common name of the product and must appear on the front of the package. The product name should be in bold, largest type, and should provide an accurate description of the product.
2. Net quantity of contents: The net quantity of the contents of the container must appear at the bottom portion of the label on the PDP. This is where you declare the product weight in not only U.S. customary units but also using metric system units. For example: “Net Wt. 10.5 OZ. (298 g)”. The product can be described in either weight for solids, (e.g. ounces, grams) or volume for liquids (e.g. fluid ounces or milliliters).
   
   The PDP’s size will determine how big the letters can be and the font size that can be used on the package. In most cases, letter size should be no less than 1/16” in height based on the lower case ‘o’ (HHS, 2013).

Note: If there are two or more sections of the package that could be suitable for the PDP, one surface becomes the Alternate Principle Display Panel (APDP, fig. 1). Think about the front and back of a cereal box.

2) Information Panel

The information panel is directly to the right of the PDP. By regulation, it must contain:

1. List of ingredients: All ingredients must be listed in descending orderer by weight or volume. In other words, the ingredient that weighs the most is listed first and the ingredient that weighs the least is listed last (HHS, 2013). If an ingredient has multiple components, all components must be listed in parentheses following the ingredient. For example: Mustard (vinegar, water, mustard seed, salt, turmeric, paprika, spices, and garlic powder).
   Additionally, the eight major allergens (dairy, eggs, peanuts, seafood, shellfish, tree nuts, soy, and wheat) must also be identified in the ingredients list (figure 2A). These can be include within the ingredient list, or as a separate statement. For example: “This product contains wheat.” (figure 2B)
2. Contact information: The full name and address (PO Box is not acceptable) of the manufacturer, packer, or distributor of your product must be included. The address must include street number and street name (if not listed in a directory or telephone book), city, state, and ZIP code.
3. Nutrition Facts Panel: This is the portion of the label that breaks down the contents of your product by nutrient and health claims (see fig. 3 ). Some small businesses may be exempt from having a Nutrition Facts Label. For instance:
   Retailers with less than $500,000 in gross annual sales of all types of products (food and non- food)are exempt.

What are nutritional labeling panel claims?

Nutritional labeling claims are claims stating, suggesting, or implying that a food or food ingredient has specific nutritional benefits. The FDA has a list of all nutritional claims allowable by law; all claims must follow the FDA’s guidance. Some examples of common claims include “low-fat,” “sugar-free,” and “a good source of ...”
Generally, there are three types of claims: health claims, nutrient content claims, and structure/ function claims.

1. Health claim: A claim on a label that directly states or implies that the food product provides some benefit that helps with a disease or health condition.
   Note: All health claims approved for use are listed in the labeling guide (HHS, 2013). These must be approved by the FDA who verifies the relationship between the food product and the health condition. Examples include, “A diet low in sodium may [or might] reduce the risk of high blood pressure,” and “A diet low in saturated fat and cholesterol may reduce the risk of heart disease.”
2. Nutrient content claim: A claim on a label implying a certain level of nutrients is available in the product. Most nutrient claims apply to the amount of nutrient provided by one serving size in relation to a 2,000-calorie intake per day. Examples include “-free,” “reduced,” “lite,” or “high” when referring to a specific level of nutrient (e.g., fat, sugar, vitamin, etc.).
3. Structure/function claims: A claim on a label that indicates that an ingredient in the product has an effect on a function in the human body, but is not related to a specific disease. For example: “Calcium builds strong bones”.

Additional Resources

Virginia Cooperative Extension. 2012. Making a Nutrient or Health Claim. VCE publication FST-54NP. https://pubs.ext.vt.edu/content/dam/pubs_ext_vt_edu/FST/FST-54/FST-54NP_PDF.pdf.

Virginia Department of Agriculture and Consumer Services. n.d. Basic Labeling Requirements. www.vdacs.virginia.gov/vafinest.com/pdf/requirements.pdf.

Virginia Department of Agriculture and Consumer Services. 2017. “Labeling Guidelines,” 58-61. In Handbook for Small Food Manufacturers. www.vdacs.virginia.gov/pdf/va-food-handbook.pdf.

Reference

U.S. Department of Health and Human Services (HHS). 2013. A food labeling guide: guidance for industry. www.fda.gov/FoodLabelingGuide

Virginia Cooperative Extension. 2012. Know Your Way Around a Food Label. VCE publication FST-53NP. https://pubs.ext.vt.edu/content/dam/pubs_ext_vt_edu/FST/FST-53/FST-53NP_PDF.pdf.