FDA Nutrition Facts Label Requirements (2026): A Practical Guide for Small Food Businesses

If you sell packaged food in the United States, the Nutrition Facts panel on the back of the pack is not decoration — it is a regulated document governed by 21 CFR 101.9. Getting it wrong is one of the most common reasons small food businesses get a warning letter or a rejected retail listing. This guide walks through what the rules actually require, in plain language, without pretending the regulation is simpler than it is.

Who actually needs a label?

Most packaged foods offered for retail sale require a Nutrition Facts panel. But there are real exemptions. Food served for immediate consumption (a restaurant plate, a deli sandwich made to order) is generally exempt, as are foods with no meaningful nutritional value such as plain coffee beans or most spices. The exemption that matters most to small producers is the small-business exemption, covered at the end of this article.

The 2016 format is now the only format

The FDA finalized a redesigned Nutrition Facts panel in 2016, and the compliance deadlines (January 2020 for larger manufacturers, January 2021 for those under $10 million in annual food sales) are long past. Every label you print today must use the current format. The visible differences from the old panel are:

• A larger, bolder Calories figure.
• Serving sizes updated to reflect what people actually eat, and a bolded 'servings per container' line.
• 'Added Sugars' listed as a mandatory sub-line under Total Sugars, with its own %DV.
• Vitamin D and Potassium are now mandatory (with actual amounts in mg/mcg); Vitamins A and C are no longer required.
• Updated Daily Values — for example, Total Fat DV is 78 g, Sodium is 2,300 mg, and Dietary Fiber is 28 g.

The mandatory nutrients

The core panel must declare, in order: Total Fat, Saturated Fat, Trans Fat, Cholesterol, Sodium, Total Carbohydrate, Dietary Fiber, Total Sugars, Added Sugars, and Protein — plus the four mandatory micronutrients Vitamin D, Calcium, Iron, and Potassium. Calories sit at the top. Each nutrient carries a % Daily Value except Trans Fat, Total Sugars, and Protein (protein %DV is optional unless you make a claim about it).

“It is critical that this is done in a way that minimizes unnecessary costs while providing consumers with clear, consistent and science-based nutrition information.”

That tension — clarity for shoppers without piling unnecessary cost onto producers — is really what 21 CFR 101.9 is trying to balance. It's worth keeping in mind when a rule feels bureaucratic: most of the specificity exists because a vaguer rule would let two similar products present wildly different-looking numbers for the same underlying nutrition, which helps no one at the shelf.

Rounding rules are not optional

This is where most DIY labels go wrong. 21 CFR 101.9 specifies exactly how each nutrient is rounded, and the increments differ by nutrient and by magnitude. A few of the most-used rules:

• Calories: round to the nearest 5 below 50 cal, and to the nearest 10 above 50 cal. Under 5 cal is expressed as 0.
• Total Fat, Saturated Fat, Trans Fat: to the nearest 0.5 g below 5 g, and to the nearest 1 g above 5 g. Under 0.5 g is 0.
• Sodium: to the nearest 5 mg between 5 and 140 mg; to the nearest 10 mg above 140 mg; under 5 mg is 0.
• Total Carbohydrate, Fiber, Sugars, Protein: to the nearest 1 g (with amounts under 0.5 g expressed as 0, and 0.5–1 g as 'less than 1 g').
• % Daily Values are calculated from the rounded amount is a common myth — %DV is computed from the actual (unrounded) quantity, then the result is rounded to the nearest whole percent.

Serving sizes and the RACC

You do not get to pick a flattering serving size. Serving sizes are anchored to the Reference Amount Customarily Consumed (RACC) — a table of reference amounts the FDA publishes by food category (for example, 30 g for most crackers, 55 g for a muffin, 240 mL for most beverages). Your declared serving size must be based on the RACC for your product's category and expressed in both a household measure (cups, pieces) and metric weight in grams. Products packaged as a single serving, or in the 200–300% of RACC range, have their own dual-column rules.

A co-packer's compliance review is where this most often gets caught. One small-batch cracker producer we heard from had declared a serving size matched to 'what feels like a portion' rather than the RACC for crackers — their co-packer's own compliance check bounced the label back before the first production run, and the whole batch of pre-printed packaging had to be reprinted at the producer's cost. Checking the RACC table before you finalize artwork, not after a co-packer flags it, is the cheaper way to find out.

Allergens: the 'Contains' statement and FALCPA

Allergen labeling is governed by FALCPA, not by the Nutrition Facts panel itself, but it lives on the same package and trips up just as many producers. FALCPA requires that any of the major food allergens be declared in plain English, either in the ingredient list or in a separate 'Contains' statement immediately after or adjacent to it (for example: 'Contains: Wheat, Milk, Soy'). As of the FASTER Act, sesame became the 9th major allergen effective January 1, 2023, so the current big-9 are:

• Milk
• Eggs
• Fish
• Crustacean shellfish
• Tree nuts
• Peanuts
• Wheat
• Soybeans
• Sesame

The declaration must name the specific type where relevant — 'walnuts' rather than just 'tree nuts', 'cod' rather than just 'fish'. Mealary screens your ingredient list for the big-9 automatically and drafts the 'Contains' line for you to verify.

The small-business exemptions

Two exemptions matter most to small producers, and they are separate things:

1. The low-volume exemption (21 CFR 101.9(j)(18)): if you have fewer than 100 full-time-equivalent employees and sell fewer than 100,000 units of that product nationally per year, you can file a short notice with the FDA and skip the Nutrition Facts panel — provided you make no nutrient content or health claims.
2. The small-business exemption (21 CFR 101.9(j)(1)): businesses with fewer than an average of 100 FTE employees and fewer than 100,000 units sold per year are generally exempt without even filing, subject to the same 'no claims' condition.

The catch is the claims trigger. The moment you print something like 'low fat', 'good source of fiber', 'high protein', or 'zero sugar', you forfeit the exemption and a full compliant panel becomes mandatory. Many small producers quietly rely on an exemption they've already voided with a single marketing word on the front of the pack.

A pragmatic checklist

• Confirm whether you're exempt — and whether any front-of-pack claim voids that exemption.
• Set the serving size from the correct RACC category, in household + gram measures.
• Compute nutrients per serving from a reliable database (USDA FoodData Central), then apply the 21 CFR 101.9 rounding.
• List ingredients in descending order of weight.
• Add the 'Contains' statement covering the big-9, sesame included.
• Verify against your final production formulation before you print — a computation is a starting point, not a legal sign-off.

None of this requires a consultant for a straightforward product. It does require getting the arithmetic and the rounding exactly right, every time — which is precisely the part worth automating. For the exact Daily Value figures and dual-column triggers referenced above, see our FDA nutrition label guidelines guide; for a line-by-line walkthrough of the panel itself, our complete Nutrition Facts label guide covers every mandatory element in depth. If you're a home-based producer rather than a manufacturer, our cottage food labeling guide explains how these federal rules interact with state cottage food law.