As a brand and/or manufacturer of food products or facilitating imports or distribution in the U.S., the FDA is not just a term. Creating FDA-compliant artworks and labels is a practiced art in itself.  

The FDA regulates multiple aspects of food supply and categories. To ensure the security of public health and meet increasing health demands, the FDA has many established guidelines, laws, and statements. 

Understanding and collating all the data to brief creative teams for food labeling projects can seem like an uphill task.    

If you've visited the FDA website, you’d recognize the feeling of going down a rabbit hole for sure. The vast amount of information on the website, with interlinking guides and articles, might be overwhelming and confusing. 

But, don't fear. 

For you, we read and untangled the data to list down the necessary food labeling guidelines and their criteria. 

In this FDA food labeling guide, you'll get a snapshot of: 

• FDA guidelines for food and beverage labels
• A brief understanding of different terms (Everything from PDP to NCC. What's that? Read on!)
• A free checklist to simplify the food labeling process for you

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Disclaimer: This blog post derives information from the U.S. Food and Drug Administration (FDA) website and is updated as of March 1st, 2024. Do refer to the FDA website for final and updated information regarding regulations. Artwork Flow is a software designed to streamline compliance for brands, not a service providing legal or regulatory advice.

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The Role Of The U.S. Food And Drug Association 

Established in 1906, the Food and Drug Association or FDA is a federal agency of the United States Department of Health and Human Services.  

The FDA is responsible for protecting public health by regulating the safety, use, and security of food supplies and products.  

However, when you see 'FDA Approved' written prominently on food products, be aware. That’s because the agency does not pre-approve or certify a food product before it is marketed and distributed in the United States of America.

Brands, manufacturers, and importers are responsible for understanding mandatory regulations, ensuring the right information is present, and remaining aware of any changes.

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Food Labeling Requirements As Stated By The FDA

I. Principal Display Panel

1. Statement of Identity

2. Net Quantity

II. Information Panel

1. Ingredient List

2. Instructions to Use 

3. Manufacturer Name & Address

4. Country of Origin

5. Product Code

III. Nutrient Panel

1. Nutrient Labeling

2. Serving Sizes

IV. Claims And Warnings

1. Food Allergen Declarations

2. Nutrient Content Claims

I. Principal Display Panel

The term Principal Display Panel a.k.a. PDP refers to the front part of a food product packaging or labeling. It's often the first thing a customer sees on a retail or e-shelf. 

The principal display panel shall be large enough to accommodate all the mandatory label information required to be placed thereon by this part with clarity and conspicuousness and without obscuring design, vignettes, or crowding.

Graphic requirements

The PDP should accommodate all the necessary information that is legible and concisely explain the product.    

The area of the principal display panel is calculated by the shape of the packaging or the product:

(i) Rectangular shape: The PDP is the entire customer-facing side, the product of the height times the width of that side;

(ii) Cylindrical shape: The PDP is 40% of the product of the height of the container times the circumference.

(iii) Other shapes: The PDP is 40% of the total surface of the container.

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2. Statement of Identity

The statement of identity refers to the common name of the food product. The statement of identity helps customers to know exactly what product they are purchasing.   

E.g., in the below picture, Quaker is the product name, and 'Oats' is the statement of identity.    

Graphic requirements

On the PDP, the statement of identity should be in bold type, reasonably sized with other information, and generally parallel to the base of the package.

3. Net Quantity

Net quantity refers to the amount of food in the container. It helps the customer determine how much to buy.

If the food product is solid, semi-solid, or viscous, the net quantity is expressed in terms of weight. If it's a liquid form, then it's expressed in a fluid measure. The net contents should be displayed in both metric (grams, kilograms, milliliters, liters) and U.S. Customary System (ounces, pounds, fluid ounces) terms. 

Keep in mind that the net quantity does not include the weight of the container, or wrappers and packing materials. 

Graphic requirements

Net Quantity is generally placed in the bottom 30% of the PDP and parallel with the base of the container. Additionally, it should be displayed in a prominent print style and contrast with the background color or artwork.

II. Information Panel

Graphic requirements

The information panel should be located immediately to the right of the PDP.

1. Ingredient list

In this part of the label, the ingredients are listed in descending order of predominance. It helps customers to know specific ingredients and purchase products depending on their preferences.  

Graphic requirements

The ingredient list is placed either on the same label panel as the name and address of the manufacturer/distributor or before or after the nutrition label.

2. Instructions to use 

It helps customers to know how to correctly prepare or handle food products at the right temperature. 

Also, storage directions such as 'Refrigerate after opening', and 'Keep in a cool dry place' slow down bacterial growth so customers can safely store food products.    

3. Manufacturer and distributor details

FDA laws dictate the name, address, batch number, lot identification, and license number of the manufacturer, packer, or distributor to lend authenticity to products. If there are any defects, these details offer the FDA and/or customers a way to contact, send any queries, and trace the products through the supply chain.  

4. Country of origin

The FDA requires food products to state the country of origin. This detail helps customers to know where the food product was manufactured or produced. 

Graphic requirements

The country of origin statement must appear near the manufacturer's name and address and be at least comparable in size to the lettering.

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5. Product code

The product code according to the FDA describes a specific product and contains a combination of five to seven numbers and letters. E.g., Food Product

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The letters and numbers represent five components: 

Industry code - A two-digit number that determines the broadest area into which a product falls. 

Class - One letter (A-Z) is directly related to the product category. 

Subclass - One letter (A-Z) that represents the container type or the packaging material.

Process Indicator Code (PIC) - One letter (A-Z) that describes the process, storage, or dosage form depending on the type of product.

Product (Group) - These are 2 characters which can be either letters or numbers and it identifies the particular product. 

Use the Product Code Builder Application tool built by the FDA to determine your product code.  

III. Nutrient Panel

The Nutrient Panel is part of a food label where the nutritional information is present. In recent years, keeping in mind customer concerns and alarming health studies, the FDA has focused on revising this panel to be as informative as possible.

Graphic requirements

In terms of placement, the nutrient panel can be placed with the ingredient list and manufacturer details.

1. Nutrition details

Here's where customers will get a detailed look at the nutrients present in the food product. This information allows customers to review the nutrients and their measurements and ensure the products suit their dietary choices.  

So, what's included in the nutrient panel?

Name and values of nutrients including calories, total fat, saturated fat, trans fat, cholesterol, sodium, carbohydrates, proteins, vitamins, and minerals.

Graphic requirements

According to the FDA, nutrition information must be displayed in a box. Here's a quick glimpse of the graphical representation of the panel:

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2. Serving sizes

As you might have noticed from the above image, serving size is a part of the nutrient panel. However, this tiny bit of information requires quite a bit of thought. That's why we would like to explore this aspect in more detail. 

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So, how does the FDA define 'serving size'?

Serving size is defined as the amount of food that will be consumed by a customer, generally on a single occasion.  E.g., the reference amount to set a serving of ice cream is 2/3 cup and soda is 12 ounces. 

RACC helps to formulate the serving size for food products. Serving size helps customers gauge how long the food product might last for how much can be consumed and purchase accordingly. 

IV. Claims and Warnings

Recently, Summer Fresh Salads Inc. had to recall its Wegmans Harissa Hummus Topped With Harissa because it may have contained undeclared sesame. In similar news, Trader Joe's did a recall of certain products containing Cotija Cheese because they could contain Listeria Monocytogenes which can cause foodborne illness.

Such inaccuracy in labeling artworks can severely hurt a brand's market positioning.

So, what type of claims and warnings should you state on your food product?  

1. Avoid recalls due to undeclared food allergens 

Under the Food Allergen Labeling and Consumer Protection Act of 2004, the FDA has laid out directives for declaring certain food allergens.

FDA estimates around 90% of all food allergies to be caused by the following major food allergens: Milk, egg, fish, Crustacean shellfish, tree nuts, wheat, peanuts, and soybeans. 

So, if your product contains these ingredients or any ingredients derived from them, be sure to declare them in the ingredient list and also on the PDP. 

2. Avoid misleading your customers

As stated before, the FDA closely mandates the nutrients panel. Before you make any nutrient claims, be sure to know which words are acceptable. 

FDA has defined many Nutrient Content Claims (NCC) and their parameters. Please check the FDA's nutrient claims section for other terms. Also, brands cannot use any nutrient claim currently not present in the database.  

We're exploring some popular implied nutrient content claims that are often used by brands. 

Good source of ____

This term can be used on a product label only if the food product contains 10%-19% of the DV. 

High in _____ 

This term can be used on a product label only if the food product contains at least 20% of the DV. 

Free of ____ or Low in _____

These terms can be used under certain parameters stated by the FDA. 

E.g., 1) Brands can only use Calorie Free/Zero Calories if the product contains less than 5 calories per labeled serving. 

2) Brands can use Low Fat only if the product contains 3 g or less fat per serving if the reference amount is 30 g or less. 

Healthy 

You can use 'healthy' or any related terms on your product artwork. However, to use this term, the food product should have a lesser limit of nutrients including total fat, saturated fat, cholesterol, and sodium, and contain at least 10% of certain nutrients to encourage in the labeled serving size or RACC.       

Fresh 

A food product can only be labeled as 'Fresh' when the food is unprocessed. The food should be in a raw state, has not been frozen, or has undergone any form of thermal processing or preservation, except:

• Addition of approved waxes or coatings.
• Post-harvest use of approved pesticides.
• Mild chlorine wash or mild acid wash on produce.
• Treatment of raw foods with ionizing radiation is not to exceed the maximum dose of 1 kilogram.

Fresh Frozen

If the food product has been quickly frozen while it was fresh, then terms such as 'Fresh Frozen' or 'Quickly Frozen' can be used on the label.  

Graphic requirements

Nutrient Content Claims should be accompanied by disclosure statements. They cannot be more than twice the size or prominence of the statement of identity. If the claim is unduly prominent compared to the statement of identity, it will violate the regulations.

FAQs

• What are the 7 parts of food labels?‍

The seven parts of a food label are serving size, calories, nutrient information, ingredients, percent Daily Value, allergens, and manufacturer information.

• What are the 4 types of food labels?

The four types of food labels are the nutrition facts label, health claims, ingredient lists, and allergen warnings. These labels provide important information about the contents of packaged foods.

• What are the 3 main purposes of a food label?

The three main purposes of a food label are to provide information about the product's ingredients, nutritional value, and allergens to help consumers make informed choices about what they eat.

• What are the 2 most important parts of the food label?

The two most important parts of a food label are the Nutrition Facts panel, which provides information about the product's nutrient content, and the ingredient list, which lists all the ingredients used.

• Which label panel is the information panel?

The information panel is the label panel immediately to the right of the PDP, as displayed to the consumer. If this panel is not usable due to package design and construction, (e.g., folded flaps), then the information panel is the next label panel immediately to the right.

• Should modified statements of identity be used for sliced and unsliced (e.g., cheddar cheese) versions of a food? 

Labels must inform you of the form of the food in the package if the food is sold in different forms such as sliced and unsliced, whole or halves, etc.

• I have a 100% juice drink and a non-juice ingredient. May I still call it 100% juice?

If the added ingredient does not dilute the juice or, change its volume, you may call it 100% juice but the percent juice statement must identify the added ingredient, e.g., “100% juice with added preservative.” 

• Should water be specified as an ingredient? 

Water added in making a food is considered to be an ingredient. The added water must be identified in the list of ingredients and listed in its descending order of predominance by weight. Water does not need to be declared as an ingredient if it is removed during processing by baking or by some other means.

• How many samples of each product should we study for nutrition labeling? 

FDA has not defined the number of samples that must be analyzed. A manufacturer, packer, or distributor is responsible for determining the variability of their product(s) and the number of samples necessary to provide accurate nutrient information.

Easily comply with FDA guidelines using Artwork Flow

Now that you've got a good idea of the necessary FDA requirements, it's time to get cracking on your food label. 

Starting a complex food label project? Imagine having to go through dozens of creatives every day while also checking if they meet the latest FDA guidelines. Well, say goodbye to those days! 

Artwork Flow’s label management software can help you break it down with its ComplyAI feature. You can scan your creatives like a robot by creating your own rulesets and running through them. If you have any red flags in your creatives, the ComplyAI tool will highlight them. But how? Assume your tetra pack of fresh orange juice is undergoing compliance testing before it reaches the public.

With your customizable rulebook, you can add phrases like "artificial flavors" and "preservatives" under restricted keywords, and "no sugar added" under favored keywords. The tool checks it and notifies you of the presence or absence of any of these terms. This way, you can easily check the copy without having to lean forward from your chair. 

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To learn more about how ComplyAI can help streamline your compliance process, book a demo with Artwork Flow!

Also, get your hands on our FREE checklist designed especially for your food labeling requirements. We recommend you share this with your teams and collaborators to increase their familiarity with certain food labeling terms and conditions. 

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