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-complaint 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 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, the feeling of going down the rabbit hole is not entirely untrue. The vast amount of information on the website, with interlinking guides and articles, might be overwhelming and confusing.
But, don't fear.
For you, I read and untangled the data to list down the necessary food labeling guidelines and their criteria.
In this food labeling guide, you'll get a snapshot of:
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 supply 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 label before its 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.
1. Brand Elements
2. Statement of Identity
3. Net Quantity
1. Ingredient List
2. Instructions to Use
3. Manufacturer Name & Address
4. Country of Origin
5. Product Code
1. Nutrient Labeling
2. Serving Sizes
1. Food Allergen Declarations
2. Nutrient Content Claims
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.
The PDP should accommodate all the necessary information that is legible and concisely explains the product.
The area of the principal display panel is calculated by the shape of the packaging or the product:
Rectangular Shape: The PDP is the entire customer-facing side.
Cylindrical Shape: The PDP is 40% of the product of the height of the container times the circumference.
Other Shapes: The PDP is 40% of the total surface of the container
Brand elements on the PDP include logo, tagline, variant (flavor or major ingredient), and artwork of the food product.
The FDA doesn't have any mandatory requirements in regards to brand elements. However, the elements should be in a legible font and appealing color schemes that catch a customer's eye.
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, 'Oats' is the statement of identity.
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.
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.
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 to the background color or artwork.
The information panel refers to the part of the food label where the most relevant information is present.
The information panel should be located immediately to the right of the PDP.
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 preference.
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.
Instructions to use help customers to know how to correctly prepare or handle food products at the right temperature.
Also, storage directions such as 'Refrigerate after opening', 'Keep in cool dry place' slows down bacterial growth so customers can safely store food products.
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.
Also, the FDA doesn't necessarily require any dates on food products except for infant formula. However, as part of the White House's initiative to reduce food waste, the FDA supports and encourages the use of the term “Best if Used By” on packaged-food labeling if the date is simply related to optimal quality.
FDA requires food products to state the country of origin. This detail helps customers to know where the food product was manufactured or produced.
The country of origin statement must appear near the manufacturer's name and address and at least comparable in size of the lettering.
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
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) which 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 FDA to determine your product code.
The Nutrient Panel is the 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 its efforts on revising this panel to be as informative as possible.
In terms of placement, the nutrient panel can be placed with the ingredient list and manufacturer details.
Here's where customers will get a detailed look at the nutrients present in the food product. This information provides customers to review the nutrients and their measurements and make certain 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.
According to the FDA, nutrition information must be displayed in a box. Here's a quick glimpse of the graphical representation of the panel:
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.
So, how does 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.
RACC helps to formulate the serving size for food products. Serving size helps customers to gauge how long the food product might last for how much can be consumed and purchase accordingly.
Recently, Whole Foods had to recall 10 variants of Macaroni & Cheese Products from stores across five states because they contain undeclared egg. In similar news, Trader Joes did a massive recall of around 4000 pounds of frozen fish products because they contain undeclared wheat and milk ingredients.
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?
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.
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.
This term can be used on a product label only if the food product contains 10%-19% of the DV.
This term can be used on a product label only if the food product contains at least 20% of the DV.
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.
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.
A food product can only be labeled as 'Fresh' when the food is unprocessed. The food should in a raw state, has not been frozen, or has undergone any form of thermal processing or preservation, except:
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.
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.
The effect of COVID-19 has been far-reaching and food safety has become paramount. During a crisis, authorities such as the FDA can bring order to chaos and that's exactly how they are helping the public.
Early on, the FDA released temporary food labeling guidelines to reduce any supply disruptions, especially during lockdowns and shelter-in-place orders.
To make sure that food manufacturers could reach their customers with on-hand inventory, the FDA stated that they wouldn't object to the sale of packaged food without a nutrition facts label. However, brands can't make any nutrient content claims.
For the safety of public health, the FDA is firm that food products should have the following information on the label:
Now, that you've got a good idea of the necessary FDA requirements, it's time to get cracking on your food label.
You can use this food labeling guide as a reference point to build a checklist. Also, we recommend you share this with your teams and collaborators to increase their familiarity with certain food labeling terms.
Starting a food label project? Tell us your tips in the comments below!