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FALCPA & US Allergen Law10 October 20258 min read

US Nutrition Facts Label Requirements: What Food Brands Must Display

The FDA Nutrition Facts label is mandatory on most packaged food sold in the US. Here is what food brands need to know about current Nutrition Facts label requirements.

The Nutrition Facts label is mandatory on most packaged food regulated by the FDA. The most recent major update to the Nutrition Facts label format (effective for most manufacturers in 2020–2021) introduced several significant changes that food brands must now comply with.

What the Current Nutrition Facts Label Must Show

  • Serving size: Updated to reflect amounts people actually eat (not aspirational servings)
  • Calories: Displayed in larger, bolder font
  • Nutrients: Total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fibre, total sugars, added sugars (new), protein, Vitamin D (new), calcium, iron, potassium (new)
  • % Daily Value: Based on a 2,000 calorie daily diet

Added Sugars: The New Requirement

The most significant change in the updated label was the mandatory declaration of "added sugars." This is separate from naturally occurring sugars and reflects the sugar added during production. Food brands with high added sugar content should expect this to be a consumer concern.

Small Business Timelines

Small manufacturers (less than $10 million in annual food sales) had an extended compliance deadline. As of 2021, virtually all manufacturers should now be using the updated format.

Online Product Pages

While the Nutrition Facts label requirement is for physical packaging, displaying nutrition information on your Shopify product pages is both good practice and expected by health-conscious US consumers.

Manage allergen and dietary information for your US Shopify store products with Allergen Matrix at saltai.app.

Which Products Are Exempt from the Nutrition Facts Label

Not every food product sold in the United States requires a Nutrition Facts label, and understanding these exemptions can help small food brands prioritise their compliance efforts. The FDA exempts certain categories from mandatory labelling, including plain coffee and tea, most spices and flavourings, and some restaurant-style foods sold at the point of purchase. However, any health claim made on the packaging — such as "low sodium" or "high in fibre" — immediately triggers the labelling requirement regardless of the product category, so brands need to be careful with their marketing language.

Raw fruits, vegetables, and fish are also technically exempt, though voluntary nutrition labelling programmes exist for these categories. Retailers selling significant volumes of these products are encouraged to participate in FDA voluntary programmes, which provide point-of-sale nutrition information through posters, booklets, or shelf labels. If your Shopify store ships raw or minimally processed goods into the US, it is worth reviewing whether your specific product type falls under any of these exemptions before investing in full label design and laboratory testing.

Small food manufacturers should also be aware that exemption status can change if annual sales volumes increase or if the product is sold through certain retail channels. Businesses that start as cottage-industry operations and grow into multi-state distributors may find themselves crossing thresholds that remove previously applicable exemptions. Reviewing your eligibility annually, particularly at the start of each financial year, is a sensible habit that prevents compliance gaps from developing unnoticed as your brand scales.

How Serving Size Rules Work in Practice

Serving size on the updated Nutrition Facts label is no longer left to the manufacturer's discretion in the way it once was. The FDA now mandates Reference Amounts Customarily Consumed (RACCs) for different food categories, which are standardised serving sizes based on how Americans actually eat these foods according to consumption surveys. For example, a beverage RACC is typically 240ml (8 fl oz), and a cookie RACC may be 30g. If your product serving size differs significantly from the RACC, you are required to use the RACC value, not your preferred portion.

For packages that contain between one and two servings based on the RACC, the entire package must now be declared as a single serving. This has significant implications for products like energy drinks, single-serve snack bags, and individual dessert portions, where manufacturers previously listed two servings per container to make calorie counts appear lower. The FDA closed this loophole deliberately, and the resulting single-serving declaration means that calorie and nutrient values must reflect the full package contents, which can substantially change how a product appears to health-conscious shoppers.

Dual-column labels are required for certain packages — those that could reasonably be consumed in one sitting but contain between two and a half and less than five servings. This format shows nutrition information both per serving and per full package simultaneously, giving consumers immediate clarity without any calculation. If you manufacture products like sharing bags of nuts or multi-portion pasta pouches that fall into this middle ground, you should confirm whether the dual-column format applies to your specific packaging. Getting this detail right from the outset saves costly label reprints later.

Vitamin and Mineral Declaration Changes

The updated Nutrition Facts label retired the previously mandatory declarations of Vitamins A and C, replacing them with Vitamin D and potassium. This shift reflects current public health priorities: deficiencies in Vitamin D and potassium are more prevalent in the US population today than deficiencies in Vitamins A and C. Calcium and iron remain mandatory. While Vitamins A and C are no longer required, brands may still voluntarily declare them, and many do, particularly those marketing to families or health-focused demographics who associate these nutrients with specific benefits.

Potassium is now a required nutrient, and this catches some brands off guard, particularly those whose products were tested and labelled before the rule update. Laboratory testing must specifically include potassium analysis if your existing nutritional data predates the 2020 requirements. If you are working from an older nutritional breakdown, it is worth commissioning updated testing rather than assuming your existing data is complete. Incomplete or inaccurate % Daily Value declarations for required nutrients can result in FDA warning letters and costly reformulation or relabelling exercises.

The % Daily Values themselves were also updated as part of the 2016 rule that phased in by 2021. The Daily Reference Values for nutrients like sodium, dietary fibre, and Vitamin D changed, which means the % DV figures on older labels may now be mathematically incorrect even if the absolute gram amounts were accurate. Food brands selling into the US should audit any label that was designed before 2020 to ensure the % DV calculations reflect the current reference values. This is a subtle but meaningful compliance issue that affects a surprisingly large number of products still in circulation.

Formatting and Design Requirements for the Label

The FDA specifies not just what information must appear on the Nutrition Facts label but precisely how it must be presented. Type size minimums, bold weight requirements, the hierarchy of information, and the overall box format are all regulated. Calories must appear in a type size of at least 24 points, with the word "Calories" set no smaller than 16 points. The serving size must also appear prominently. Brands that redesign their packaging for aesthetic reasons sometimes inadvertently violate these typographic rules, particularly when working with designers who are not familiar with FDA label regulations.

The label must use a vertical format in most cases, though a linear or tabular format is permitted when the package surface area is too small to accommodate the standard layout. Small packages — those with less than 40 square inches of available label space — have specific alternative formatting rules that reduce the minimum type sizes and simplify the presentation. If you are launching a product in a very small format, such as a single-serve sachet or a miniature condiment bottle, you should review the FDA's small package guidelines before finalising your design to ensure you are using the correct permitted alternative.

Colour contrast is also regulated: the label must appear in black type on a white background wherever possible, and any use of colour must maintain sufficient contrast for legibility. Some brands attempt to integrate the Nutrition Facts panel into creative packaging by using coloured backgrounds, reversed text, or decorative borders, which can create compliance issues. The FDA permits certain exceptions, but these require careful documentation and are generally not worth the risk for brands without dedicated regulatory affairs support. Working with a food labelling specialist during your packaging design process is the most reliable way to avoid these formatting pitfalls.

Implications for Shopify Stores Selling Food into the US

If you operate a Shopify store and ship packaged food products to US customers, your compliance obligations extend beyond the physical label on the package. US consumers increasingly expect to find nutrition information on product pages before they make a purchase, and the absence of this information can reduce conversion rates and increase customer service queries. While the FDA's Nutrition Facts label rules technically apply to physical packaging, presenting accurate nutrition data online demonstrates the transparency that modern food shoppers expect, particularly in health-conscious categories.

Displaying allergen information alongside nutrition data on your product pages creates a more complete and trustworthy product listing. The two categories of information are deeply connected in the minds of careful shoppers, and brands that present both clearly tend to earn stronger customer confidence. For Shopify merchants managing multiple products with varying nutritional profiles, keeping this data organised, accurate, and consistently displayed across your store is a practical challenge that the right tooling can solve efficiently.

Manage allergen and dietary information for your US Shopify store products with Allergen Matrix at saltai.app.

Try Allergen Matrix free at saltai.app — no credit card required.

SaltAI Team

SaltAI builds focused Shopify apps for food merchants and general merchants. Every app is tested in production at a real food store — including Vanda's Kitchen — before it ships.