FDA Nutrition Facts label requirements: nutrients, type sizes and formats
Most packaged foods sold in the US need a Nutrition Facts panel under 21 CFR 101.9, in the current format with added sugars, vitamin D and potassium, a serving size based on FDA's reference amounts, and "Calories" in bold type of at least 16 point with the number at least 22 point. Small packages, some low-volume producers and alcohol regulated by TTB have exemptions or alternate formats. Tria prints the panel as a roll-fed nutrition label from 200 units in 5 to 7 business days, or lays it out on your carton or pouch artwork.
This is packaging guidance, not legal advice. We reserve the panel space and set the type to FDA's minimums; the nutrient values, serving size and claims are yours and your regulatory adviser's.
Which foods need a panel
The rule lives in 21 CFR 101.9 and covers almost every packaged food that is not specifically exempt. Any nutrient content claim, such as "low sodium" or "good source of fiber," brings back the panel even where an exemption would otherwise apply. The exemptions buyers ask us about most:
- Low-volume products. A firm with fewer than 100 full-time equivalent employees selling fewer than 100,000 units of a product a year in the US may qualify, after filing a notice with FDA (21 CFR 101.9(j)(18)). Only firms with fewer than 10 employees selling fewer than 10,000 units a year skip the notice.
- Small packages. A package with less than 12 square inches available for labeling can omit the panel if it makes no nutrition claims, provided it gives an address or phone number where consumers can get the information.
- Foods with no meaningful nutrition. Plain coffee, tea and some spices, with no claims.
- Beer, wine and spirits regulated by TTB. These follow TTB labeling rules rather than FDA's panel. Beer brewed without both malted barley and hops is the exception and falls under FDA.
Mandatory nutrients, in order
Calories; total fat, with saturated fat and trans fat indented below it; cholesterol; sodium; total carbohydrate, with dietary fiber, total sugars and "Includes X g Added Sugars" indented; protein; then vitamin D, calcium, iron and potassium. Vitamins A and C became voluntary in the current format, so drop them from old templates unless you make a claim about them. If you make a protein claim, the protein percent Daily Value becomes mandatory and has to be corrected for digestibility.
Serving size is not a marketing choice
Serving size comes from FDA's Reference Amounts Customarily Consumed, listed by food category in 21 CFR 101.12. A package holding less than 200 percent of the reference amount is generally labeled as one serving. Packages holding 200 to 300 percent generally need a dual column showing per serving and per package. A 20 ounce soft drink, for example, is one serving, because the reference amount for that category is 12 fluid ounces. Settle the serving size before you size the label, because a dual column panel is wider.
Type sizes
| Element | Minimum | Notes |
|---|---|---|
| "Nutrition Facts" heading | Larger than all other print in the panel | Except the calorie number |
| "Calories" | 16 point, bold or extra bold | 10 point in small package tabular and linear displays |
| Calorie number | 22 point, bold or extra bold | 14 point in small package tabular and linear displays |
| Servings per container | 10 point | 9 point in small package displays |
| Serving size | 10 point, bold | 9 point in tabular and small package displays |
| Nutrient names and amounts | 8 point | |
| Footnote and some other items | 6 point |
Those are minimums from 21 CFR 101.9(d), and they decide the physical size of the panel. On a small pouch, the panel is often the largest single element on the back, so we lay it out first and place the brand artwork around it.
Format options
| Format | When it is used |
|---|---|
| Standard vertical | The default for most packages |
| Dual column | Packages holding 200 to 300 percent of the reference amount, and some larger packages |
| Tabular | When the package lacks vertical space for the standard format, and on small packages |
| Linear | Small packages with 40 square inches or less available for labeling, only when a tabular display will not fit |
| Simplified | When at least eight of the mandatory nutrients are present in insignificant amounts |
| Aggregate | Variety packs with more than one food in the package |
Allergens and the ingredient list
The panel does not carry allergen information, but the label must. Nine foods are major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame, which was added from January 1, 2023 (FDA, food allergies). They are declared in the ingredient list or in a "Contains" statement immediately after or next to it. Keep the ingredient list and the Contains line together on the same panel.
Where the panel goes
The panel belongs on the information panel, which is the panel immediately to the right of the principal display panel, or on the principal display panel itself. On a carton, that is usually the right side or the back. Avoid the bottom of a box, where shoppers will not look.
Printing the panel
If your carton or pouch is already printed, or your recipe changes often, a separate nutrition label is the practical route: roll-fed, from 200 units in 5 to 7 business days, on matte stock or a gloss laminated stock for a fridge or freezer. Changing one line of the ingredient list then means reprinting a label, not a box run. For new packaging, we lay the panel out on the artwork of the stand up pouch, the snack pouch or the carton, and on jar labels as a wraparound.
Sources
- 21 CFR 101.9, nutrition labeling of food (eCFR)
- 21 CFR 101.12, reference amounts customarily consumed (eCFR)
- FDA, changes to the Nutrition Facts label
- FDA, food allergies and allergen labeling
Rules checked against these sources on October 5, 2026. Regulations change; check the current text before you print.
Questions people ask
Which products need a Nutrition Facts panel?
Almost every packaged food sold in the US that is not specifically exempt, under 21 CFR 101.9. Exemptions include some low-volume products after a notice to FDA, very small packages that make no claims, foods with no meaningful nutrition such as plain coffee and tea, and alcohol regulated by TTB. Any nutrient content claim brings the panel back.
What is the minimum type size on a Nutrition Facts panel?
In the standard format, nutrient names and amounts must be at least 8 point, serving size at least 10 point bold, "Calories" at least 16 point bold and the calorie number at least 22 point bold. Small package tabular and linear displays have lower minimums.
What is a RACC and why does it matter?
RACC stands for Reference Amount Customarily Consumed, the FDA amount listed by food category in 21 CFR 101.12. It sets your serving size. A package holding less than 200 percent of the RACC is generally one serving, and 200 to 300 percent generally needs a dual column panel.
Can a small package skip the Nutrition Facts panel?
A package with less than 12 square inches available for labeling can omit the panel if it makes no nutrition claims and gives an address or phone number for the information. Packages with 40 square inches or less can use tabular or linear formats.
Do beer, wine and spirits need a Nutrition Facts panel?
Not when they are regulated by TTB; they follow TTB labeling rules instead. Beer brewed without both malted barley and hops is regulated by FDA and follows FDA food labeling.
Can Tria print the Nutrition Facts panel as a separate label?
Yes. Our nutrition label is a roll-fed sticker for the panel, ingredients and allergen line, from 200 units in 5 to 7 business days, on matte stock or a gloss laminated stock for damp or frozen surfaces.