FDA Food Labeling Requirements

What do a package of ground beef, a box of tortilla shells, a bag of Mexican style cheese, and a jar of salsa have in common? The best answer is that, together, they make a great meal. The second-best answer is — you guessed it — that they are all subject to the Food and Drug Administration’s guidance on food labeling. 

The FDA is responsible for ensuring that food products are properly labeled. The federal Food, Drug, and Cosmetic Act and the Fair Packaging and Labeling Act are the federal laws governing food products under the FDA's jurisdiction. Like a lot of regulations, these laws are long, dense, and detailed, and certainly don’t make for easy reading (although they are great if you are having a bout of insomnia).

Fortunately, in January 2013, the U.S. Department of Health and Human Services issued a 132-page Food Labeling Guide. The guide unpacks and summarizes those dense, detailed laws on food labeling in an easier-to-understand way. 

As a very basic overview of the guide, generally (subject to several exceptions), every food label must contain the following information:

1.  A statement of identity. The statement of identity is the name of the food. The name of the food is the name established by law, or, if none, the common or usual name of the food. If the food has no usual or common name, an appropriate descriptive name should be used. 
2. A net quantity of contents statement. The net quantity of contents statement is the amount of food in the container or package. The statement must be expressed in weight, measure, or numeric count. Generally, if the food is a liquid, it should be expressed in fluid measure, and if a solid, it should be expressed by weight.
3. The name and address of the manufacturer, packer, or distributor. Every label must contain the name and address of either the product’s manufacturer, packer, or distributor. However, if the manufacturer’s name and address are not used, the name given must be accompanied by a phrase that describes the relation to the product (for example, “distributed by” or “manufactured for”).
4. An ingredient list. The ingredient list is the listing of each ingredient in the product in descending order of predominance. Unless a regulation specifically provides for a different name, the ingredient’s common or usual name should be used. If the product contains any ingredients that are major food allergens, that must be specifically declared in or below the ingredient list.
5. A nutrition facts label. The nutrition facts label contains a list of the product’s nutrition facts in one of the formats prescribed by the FDA. Examples of the formats are in the guide. 

Of course, there are many additional requirements each of these five pieces of information must meet; these requirements are all contained in the guide. The guide also discusses how the information must be displayed (i.e. font, size, and color) and where on a package this information must be displayed.

As an example, most packages have a front label panel (termed the “Principle Display Panel” or “PDP”) and an information panel (the label panel immediately to the right of the PDP). Generally, the PDP must contain the statement of identity and the net quantity statement. Generally, the information panel must include the name and address of the manufacturer, packer, or distributor, the list of ingredients, the nutrition facts label, and any required allergy labeling.

If you sell food products, I recommend that you review the guide to ensure your food label is FDA-complaint. But once you do, I’m guessing you won’t look at that box of tortilla shells in the same way next taco night!