by Lev from Recipal
You have a product. You’re ready to launch. It’s time for nutrition labels! Or is it? Let’s take a look at some general requirements the FDA has for food labeling and nutrition analysis and go over some tips for how to make sure you’ve covered your packaging essentials.
Every food label always has to have at least 4 things on its label:
The other two things you will have to include when they apply to you are: nutrition labeling and an allergen declaration. If you use any ingredients that are derived from or include any of the 8 major allergens (milk, egg, fish, shellfish, tree nuts (including coconut), wheat, peanuts, soybeans), you have to declare them on your package.
The statement of identity and net weight have to be on the principal display panel (PDP), which is usually the front of the package. With everything else that’s required, you have a choice: You can put it all on the PDP or you can put the ingredients, business identity, nutrition information, and allergens on the information panel, which is usually the part of the package just to the right of the PDP or on the back of the packaging. You just need to remember to keep the ingredients, address, allergens, and nutrition together on your package, with no intervening information.
Most CPG products will need to have nutrition facts on their product label, but there are exemptions under the FDA’s rules.
No nutrition panel is needed for the following situations:
But be aware that you can lose an exemption if you make a claim on your packaging. This is important, so we’re repeating that you will always be required to have a nutrition panel if your package includes a nutrient claim (e.g. “High in protein,” “Low sugar”, etc.). If you claim it, you have to back it up with the nutrition facts.
There are also situations when the small business exemption does not apply:
In practice, most food companies start providing nutrition facts on their labels well before they hit any of these thresholds because it’s good preparation for your business’ growth, it provides a layer of transparency for your customers, and it makes your product look even more professional.
The short answer is no! The “FDA has not stated how a company should determine the nutrient content of their product for labeling purposes.”
There are two main ways to derive nutrition facts:
Database Analysis is where you combine the known nutrition information for all the ingredients in your product to get the information for the final product. It is a perfectly acceptable method of nutritional analysis by the FDA.
If your product is very similar or identical to another product, it wouldn’t be crazy to use their nutrition information for yours. We don’t recommend this approach (aside from using it as a sense check), and you’re always ultimately responsible for what’s on your packaging, but the point is the FDA doesn’t say exactly how to come up with your nutrition information.
Food Lab Analysis is where you send your product to a food lab and they perform a chemical analysis to determine the specific nutritional composition of your product. This is beneficial if your product is highly processed.
Given that the FDA allows both lab and database analysis and does not prefer one method over the other, you’ll have to decide which best suits your product, your needs, and your budget.
Each form of analysis has its merits, but the database analysis tends to be more accurate in the long run because it relies on the average nutritional content of ingredients. The lab nutrition analysis, to the contrary, gives you the nutritional content of your product the one time you made it for the lab; that is not going to be identical to every sample of your food since ingredients, process, and measurements all change a little bit each time and especially over time.
But a lab analysis will be the better (and sometimes only option) if you’re using unusual ingredients and can’t get nutrition information for them or if you heavily process your product and want to get an accurate sense of how that affects the nutrients. So if you’re making a bone broth, a fermented food, or deep frying, the lab might be the better way to go.
In many cases with a lab analysis you will either still need to create the formatted nutrition panel using the profile you get from the lab or pay an additional fee for the formatted panel.
| Pros | Cons | |
| Lab Analysis | – The chemical analysis is done for you. – You can request additional tests and information for things other things you might want to know about your product like caffeine content. – It gives you information for items that are novel or exotic or processed. | – It is pricey—typically $750 or more per sample. – Depending on the lab, you may have to pay extra for the nutrition facts label itself and the ingredient list. – There might be issues with getting a complete analysis if something happens with the testing, and some key nutrients can be left blank. – It can take a few weeks to get results. – You need a new test each time you change a recipe or process. – There’s no test for added sugar, which is now a required part of the panel. – Testing for optional micronutrients costs extra. |
| Database Analysis | – It is usually significantly cheaper (or even free if you use ReciPal and only have one or two products or if you’re handy with spreadsheets and set up your own database analysis using the USDA nutrient data). – It can be more accurate in the long run. – There is no need to pack and ship samples for testing. – It can be completed within minutes or hours as opposed to weeks for lab analysis. – It is easy to account for recipe or process changes. | – It can be unreliable if you use more exotic ingredients and/or can’t get good nutrient data from your supplier. – It may be unreliable if the recipe or an ingredient undergoes heavy processing, which may alter the nutrient contents in a manner that’s hard to estimate. – Ingredient data might have to be collected from your suppliers when it is not already in the database. – Ingredients have to be carefully weighed before and after cooking to determine accurate measurements, particularly with recipes that involve marinades that aren’t fully absorbed or similar processes. |
As we’ve mentioned, database analysis is a great low-cost alternative to lab analysis and can even be more accurate in the long run. But for it to be a viable option and deliver that accuracy, it has to be done right. You can use a software like ReciPal to do the analysis yourself, or you can pay a consultant or company to do it for you. Either way, you’ll need to collect some information.
Most database analysis software will require similar things, so here’s our to-do list:
1. Have Your Recipe Ready.
This should go without saying, but you need to have a detailed recipe for your product, including all ingredients, amounts, and cooking processes.
2. Get Ingredient Data From Your Suppliers (If Needed).
Obtaining accurate data is usually the most time consuming process of a proper database analysis.
Most (and ideally all) ingredients in your recipe will be available in the software database. Inevitably, some will not. When you can’t find something, the best thing to do is ask your supplier for ingredient specification sheets (but you can also do your own research). These will typically include unrounded data for a 100 gram sample of the ingredient. Once you have all your spec sheets, check each one to make sure:
Once you have all your ingredient data, you’ll usually be able to enter information for ingredients you need that aren’t already there into the software database so you can use it in your analysis.
It is important to note that using data from a calorie counting website or a food label is not ideal. The data may not be correct, either because it was entered incorrectly or because the analysis was not done properly. Also this data is almost always already rounded or is based on smaller serving sizes, which reduces accuracy in your analysis.
3. Add ingredients to your recipe in the software.
4. Set the Amount you Need of each ingredient.
Once you’ve added each ingredient to your recipe, you need to set the proper amount of each one. You can set things the way you measure them in the kitchen. In general, measuring by weight rather than volume is the best way to ensure consistency and accuracy for your results.
5. Enter the Recipe Yield and Serving Information.
How you do this will vary from software to software. In ReciPal, for example, you’ll need to put in the information for
– The net weight of the package you’re selling
– How many packages the recipe makes
– How many servings are in a package and
– What the serving size is
in order for the software to calculate the proper nutritional information per serving.
The FDA has reference amounts that tell you what your serving size should be depending on the type of product you make.
It’s always a good idea to do a “sense check” of the final label in the same way you did one for ingredient information from suppliers:
Here’s the truth about nutrition analysis: it’s not perfect, and it’s not a science regardless of whether you use a lab analysis or a database analysis. Mistakes happen, and there’s room for that in the process.
First, your nutrition facts label is meant to be a helpful guide for your customers, but, by definition, it will never be exact because the FDA requires every value in the panel to be rounded.
Second, keep in mind how the information in a database is generated. When you see an entry in the USDA database, the information for it is average values calculated for many samples of that ingredient taken from various geographical locations at various times. And if the information for a product in a database comes from the nutrition label on the package of that product, the values have also already been rounded.
Third, a lab analysis isn’t more perfect because you have the information for only one sample that can’t take into account variations in production from batch to batch or differences in labs in terms of quality control or process.
The FDA takes all of this variation into account and gives you room for error. If they
audit a food label, they will check for accuracy by testing 11 samples of the product from different batches at different times of year. And even then they’re not looking for an exact match to your label. They’re checking that your numbers are within a range of their results: plus or minus 20%, depending on the nutrient. And unless it seems like you’re intentionally misleading customers, they’ll typically give you their report and have you update your labeling on your next batch of printing.
So don’t worry too much and focus on the big picture, which is giving the best useful information you can that doesn’t mislead your customers.
While it would be nice if this decision was entirely a design choice, it isn’t. The FDA has rules! Most of the time you’ll be using the standard vertical format for your nutrition panels. That’s the default and covers the majority of packaging. There is also a horizontal layout called the tabular format that you can use if you don’t have enough vertical space (about 3 inches) to fit the standard form. And there’s a linear option that you can use for small packages, but to use it you have to meet these criteria:
Note that the space available on the package is not the size of the label you choose to use, it’s essentially the surface area of your packaging (excluding parts that you couldn’t realistically put anything on, like clear windows, bottoms of stand-up pouches, etc.).
The FDA doesn’t give dimensions for the overall nutrition label. They only specify the smallest print size in the panel, which shouldn’t be less than 6 pt in the font you’re using. The key is always keeping things easy to read.
The same thing is true for how you put the panel on your product. There’s no specific requirement. You can use a stick-on label or print something directly on the package. Just make sure that whatever you decide to use works for your packaging. The label should stay put, withstand normal storage for whatever your product requires (that might be different for something frozen than it is for something that’s shelf stable), and be able to stand up to ordinary handling so that everything stays smudge-free and legible.
When it comes to nutrition labeling (and food labeling in general), be thorough and do the best you can with your analysis and presentation. The idea is to make information useful and legible. And keep in mind that the fact that it can’t or doesn’t have to be perfect isn’t the same as an excuse to be lazy about generating the information or for misleading your customers.
ReciPal makes simple software for food and beverage businesses. We help you launch and manage your food business with nutrition analysis and labeling, recipe costing, and inventory management tools – at an affordable price. You can learn more and create a free trial account at www.ReciPal.com.
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