A nutritional facts label showing the amount of servings per container.

Understanding Nutritional Facts Label Compliance

While regulations on food labels date back to the turn of the 20th century, nutrition information was sorely lacking until the 1990s. To help Americans make informed food choices, the U.S. Food and Drug Administration passed the Nutritional Labeling and Education Act, requiring food manufacturers to add a nutritional facts label that covers the most important health information for consumers in a clear, concise way. 

Standards are regularly updated to reflect new scientific evidence about nutrition and how Americans eat, so you need to stay up-to-date with new nutrition facts label requirements. 

Developing Informative Food Labels: Consumer Demand, Government Research, and Government Regulation

Until the late 1960s, there was little nutrition information included on food labels. As Americans increasingly switched from homemade foods to the ever-growing number of processed foods, healthy eating became more difficult.

On the recommendation of the White House, the FDA began the development of a system to identify nutrition in food products. In 1972, they introduced the first nutritional facts label, which was required on any food with added nutrients (or when advertising made nutrition claims). Other products had the option of using the label. Information we deem important today, like sodium and saturated fat, was optional.

In the 1980s, health organizations within the federal government wanted more information available to consumers. Meanwhile, manufacturers and independent health organizations wanted to make health claims on labels to help consumers make healthy choices. The FDA decided to take a new approach, creating a new, easy-to-read label based on research published by government agencies, including the National Institute of Health (NIH) and the Surgeon General’s office.

Serving sizes were established based on surveys of average consumption. A modified version of the FDA’s original proposal went into law in 1990 with the passage of the Nutrition Labeling and Education Act (NLEA). The format of this label was finalized in 1993. Meat, poultry, and alcohol fall outside the FDA’s jurisdiction, but every other packaged food is required to meet the NLEA’s label requirements.

These new regulations introduced the Nutrition Facts table to make it easier for consumers to understand nutrition information. Instead of only listing the amounts of nutrients, the table adds a column that lists the percent daily values in a single serving of the food

While the format of the NLEA label is nearly identical to the original proposal, its contents have changed considerably to conform to new health research. As early as 2000, changes were proposed for serving sizes to match Americans’ changing dietary habits. The required information has also changed, focusing on nutrients people are commonly deficient in while adding a separate value for added sugar

The current rules for nutrition labels were established in 2016, with compliance coming into full effect in 2022. However, these regulations are still evolving. The FDA maintains a page listing changes and proposals. These changes often take years to implement, giving manufacturers plenty of time to make their food labels compliant.

Where Do I Get Information About My Product for My Nutrition Label?

Your product needs to be analyzed by a food lab. Since this testing is so common, there are many labs out there that offer NLEA-specific packages. Most labs offer a standard package covering the NLEA’s required nutrients, while add-on tests provide data for optional statements. Foods intended for children up to 3 years old also require information about protein.

Food Label Required Information

    • Calories
    • Calories from fat
    • Total fat
    • Total carbohydrates
    • Trans fats
    • Cholesterol
    • Sodium
    • Dietary fiber
    • Sugars
    • Vitamin D
    • Calcium
    • Iron
    • Potassium

Optional Information:

    • Vitamin A
    • Vitamin C
    • Vitamin E
    • Thiamine (Vitamin B1)
    • Riboflavin (Vitamin B2)
    • Niacin (Vitamin B6)
    • Vitamin B12
    • Folate (Folic acid or Vitamin B9)
    • Biotin (Vitamin B7)
    • Pantothenic Acid (Vitamin B5)
    • Phosphorus
    • Protein, for products not marketed to young children
    • Iodine
    • Magnesium
    • Zinc
    • Copper

Additional information may be required to comply with industry best practices. For example, the American Beverage Association has guidelines for energy drinks, such as the amount of caffeine. You can learn more about these best practices in our blog entry “Important Requirements for Energy Drink Labels.” Keep in mind that there can be no “intervening material” between the required sections of the nutrition label. Any additional information, like caffeine content, must go either above or below the information required by the NLEA.

Formatting the Nutrition Facts Panel

Specifics about current panel requirements are covered in the Code of Federal Regulations 21 CFR 101.9(c)(6). If you don’t want to read dense blocks of legal jargon, the FDA has several examples of acceptable labels here. 

Nutrition Facts Panel Layouts:

    • All of the information in one column
    • Macronutrients in one column; micronutrients in two columns
    • Splitting the macronutrients into two columns
    • Listing names for nutrients on the left side, with one column listing amounts for each type of food in a multi-pack
    • Using a “per serving” column and a “per container” column
    • Removing graphical elements to create a linear label that fits on small containers

Regulations allow the nutrition facts panel to be part of the information panel or the principal display panel. The font must be at least 1/16 inch in height, measured using a lowercase “o.” The title, calories, serving size, main macronutrient categories, and all macronutrient percentages must be in bold print. The label layout is divided into four main blocks.

First block

      • Nutrition facts
      • Number of servings per container
      • Serving size, listed as volume and weight
      • Amount per serving
      • Calories

Second block

      • % Daily Value
      • Total fat
      • Saturated fat
      • Trans fat
      • Cholesterol
      • Sodium
      • Total carbohydrate
      • Dietary fiber
      • Total sugars
      • Added sugars
      • Protein, as required

Third Block

      • Vitamin D
      • Calcium
      • Iron
      • Potassium

Fourth Block

The fourth block must include the following footnote:

“The % Daily Value (DV) tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice.”

Other Information Required by the NLEA

The NLEA requires an ingredient list that includes every ingredient in order by weight, going from highest weight to lowest. Water is an ingredient if it’s added but not removed during processing. If water is added and then cooked out, it isn’t listed as an ingredient. Common names must be used, like “sugar” for sucrose.

There are two ways to list allergens on the ingredient list. They can be listed next to the ingredient containing the allergen, i.e. “flour (wheat).” Alternatively, they can be listed at the end of the ingredient list, i.e. “Contains Wheat.”

The nutrition facts panel must list the name and address of the packager, distributor, or manufacturer. If it’s produced outside of America, the country must be listed.

Get Reliable Application of Your Food Labels

Now that you’ve got an understanding of what needs to go on your nutritional facts label, make the process of labeling your product even easier with a fresh labeling system! No matter what you’re labeling, CTM Labeling Systems has the equipment you need. When you contact us, we’ll set you up with your local distributor. They’ll help you put together a labeling system that fits the needs of your production system and your customers.