By Heidi Macomber · October 18, 2026

The label proof arrives from your printer with no Added Sugars line, and the press run is scheduled for Thursday. A reprint costs as much as the first run. The missing line comes from the 2016 FDA update, which added Added Sugars to the required list, and printing without it means printing the whole run again.

Every packaged food you sell at retail carries a Nutrition Facts panel unless your business qualifies for the federal small business exemption. The rules live in 21 CFR 101.9, the FDA's nutrition labeling regulation, and they cover what must be declared, how serving size is set, which panel format fits your package, and how a low-volume business claims relief. This guide takes them in the order you will meet them: the exemption decision first, the panel contents second, the printing checks last.

Whether You Need a Panel at All: The Small Business Exemption

The exemption exists for low-volume products. You qualify if you employ fewer than an average of 100 full-time equivalent employees and you sell fewer than 100,000 units of the product in the United States in a 12-month period (21 CFR 101.9(j)(18); FDA Small Business Nutrition Labeling Exemption). For a brand-new product with no sales history, the FDA lets you count the units you reasonably expect to sell in the coming 12 months.

Three details decide how the paperwork works:

  1. The smallest sellers skip the notice entirely. If you have fewer than 10 full-time equivalent employees, are not an importer, and sell fewer than 10,000 total units of a product annually, no notice is required for that product. Keep records of your unit counts so you can show the qualification if anyone asks.
  2. Above that line, you file a notice before the period it covers. The notice goes to the FDA's Office of Nutrition and Food Labeling before the 12-month period you are claiming begins, and it lists each product, your employee count, and your unit counts. The FDA now runs an online filing system for this, the Small Business Nutrition Labeling Exemption portal, and there is no fee.
  3. Any nutrition claim voids the exemption. If your label, advertising, or website provides nutrition information or makes a nutrient content or health claim, for example "high in fiber," the exemption no longer covers that product and the full panel applies.

If you outgrow the exemption mid-year, the rule gives you 18 months from the date you no longer qualify to bring the product into full compliance.

The 15 Mandatory Entries and What Prints Bold

Every panel declares the same 15 entries (21 CFR 101.9(c)): calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, total sugars, added sugars, protein, vitamin D, calcium, iron, and potassium.

Panel line Amount required Percent Daily Value required
Calories Yes No
Total fat, saturated fat, sodium, total carbohydrate, added sugars Yes Yes
Trans fat, total sugars, protein Yes No
Cholesterol, dietary fiber Yes Yes
Vitamin D, calcium, iron, potassium Yes, in actual amounts Yes

The format rules pin the type treatments. Calories prints largest. The leading nutrient lines, total fat, cholesterol, sodium, and total carbohydrate, print in bold with their Daily Value percentages, and the indented lines beneath them, like saturated fat, total sugars, and added sugars, print in regular type.

Vitamins A and C dropped off the required list in the 2016 update and are voluntary now. One rule runs the other direction: if you add a nutrient to the recipe or make a claim about it, declaring it becomes mandatory. Fortify a granola with vitamin B12 and B12 goes on your panel.

Added sugars means sugars introduced during processing. Cane sugar in a jam counts. The naturally occurring sugars in the fruit do not. A fruit-only spread still declares total sugars, and a jam sweetened with cane sugar declares both lines. The split matters because Added Sugars carries a Daily Value percentage and total sugars does not.

Serving Size Comes From FDA Reference Amounts

Serving size is the piece operators get wrong first. It is set by FDA reference amounts customarily consumed, called RACCs, which track how much people eat of a food in a sitting. Your chosen portion does not set it. In the 2016 update the reference amount for soda moved from 8 ounces to 12 ounces, and ice cream moved from half a cup to two-thirds of a cup (FDA, Changes to the Nutrition Facts Label).

A 12-ounce bottle of lemonade is one serving even if you planned to price it as two.

Two package rules follow from the reference amount:

  1. A package holding less than double the reference amount that people typically finish in one sitting, like a 20-ounce soda or a 15-ounce can of soup, is labeled as a single serving.
  2. Larger packages holding roughly two to three times the reference amount, like a 24-ounce soda or a pint of ice cream, carry a dual-column panel showing values per serving and per package.

Panel Format Follows the Package

Four formats exist. The standard vertical panel fits containers with enough continuous vertical space. Squeeze bottles, narrow clamshells, and small tubs may qualify for a tabular format, with the nutrients in columns side by side, or a linear format, with the nutrients in a single line. The dual-column format covers the two-to-three-times packages above. The regulation sets the size tests that decide which format your package earns: packages with 40 or fewer square inches of available label space may use the tabular display, and packages under 12 square inches, or packages whose shape cannot fit a vertical or tabular display, may use the linear string format.

Type sizes scale with the panel. The rule sets minimum point sizes for the Nutrition Facts title, the serving size declaration, and the calorie line, plus the hairline separators between nutrient groups. Check these physical specs before artwork goes to the printer, because type that is one point too small makes the label noncompliant regardless of the nutrient data in it.

The Simplified Panel for Foods With Mostly Zero Nutrients

If a food contains insignificant amounts of eight or more of the 15 mandatory entries, a simplified format is allowed. It lists calories, total fat, sodium, total carbohydrate, and protein, plus any of the 15 present in more than insignificant amounts, and finishes with a "Not a significant source of" footnote naming the rest (21 CFR 101.9(f)). An insignificant amount is one that rounds to zero, or to less than 1 gram for carbohydrate, fiber, and protein. Spice blends, vinegars, and single-ingredient products commonly qualify.

Database Software Versus Lab Analysis

Panel generators, including Percy Plate, ReciPal, and meez, calculate panels from ingredient nutrition databases. That works when your recipe is assembled from packaged ingredients with supplier spec sheets. Scratch cooking introduces yield changes: a stew that loses 20 percent of its weight to evaporation changes both the serving weight and every nutrient per serving, and software that cannot apply your yield will print wrong numbers. The food yield calculator guide covers the yield side of that math. For recipes with major cooking losses, laboratory analysis of the finished product is the accurate route, and because it costs real money, most operators reserve it for their top sellers.

Rounding is part of the regulation, and your software should apply it for you. Calories round to the nearest 5 up to and including 50, and to the nearest 10 above 50, so a 47-calorie serving prints as 45 and a 72-calorie serving prints as 70. Sodium prints as zero below 5 milligrams, to the nearest 5 milligrams from 5 through 140, and to the nearest 10 above that, so 138 milligrams prints as 140. Declared serving sizes follow the reference amount rules above. Every number on your panel should trace to a recipe calculation you can reproduce, because in an inspection you have to.

Percy Plate generates the Nutrition Facts panel, ingredient labels sorted by weight, and automatic allergen detection from the same recipe data, with printing to thermal or sheet labels. The gram weights you enter for nutrition are the ones the costing side uses, so the panel and the recipe cost stay tied to one set of measurements. What stays with you: the exemption decision and its paperwork, the call on when a recipe needs lab analysis, and the final pre-print check below.

Cottage food sits under state rules, and most states exempt cottage foods from nutrition labeling entirely while still requiring an ingredient list by weight. If you sell under your state's cottage law, start with the cottage food labeling and pricing guide before assuming the federal panel applies to you.

What Changed in 2016 and What Still Trips Up New Brands

The current panel comes from the 2016 revision of the nutrition labeling rule, with compliance dates of January 1, 2020 for manufacturers with $10 million or more in annual food sales and January 1, 2021 for smaller ones (FDA, Changes to the Nutrition Facts Label). The update added Added Sugars in grams with a Daily Value percentage, moved vitamin D and potassium onto the required list with actual amounts, made vitamins A and C voluntary, removed the "calories from fat" line, enlarged the calorie line, and refreshed the Daily Values for sodium, dietary fiber, and vitamin D. Refreshed Daily Values change your percentages even when your gram amounts stay the same.

The mistakes that follow from it: printing an old template with pre-2016 Daily Values, leaving Added Sugars off, and labeling a multi-serving package without dual columns. If your label artwork predates the update or came from an old template file, regenerate it before the next print run.

The Pre-Print Checklist

  1. Panel format matches the package surface.
  2. Serving size matches the reference amount for your product category.
  3. All 15 entries are present, including added sugars, vitamin D, and potassium.
  4. Every number traces to a recipe calculation you can reproduce.
  5. Ingredient list is ordered by weight, with allergens declared.
  6. Exemption paperwork is on file if you rely on it: unit counts, employee count, and the notice confirmation if you filed one. The exemption does not excuse a false serving size or a nutrient claim.
  7. Type sizes and separators meet the format specs.

Run the list once per recipe change, and again whenever an ingredient supplier changes.

The Same Measurements Feed Your Food Cost Math

Building a panel and pricing a plate start from the same measurement: the exact weight of every ingredient per serving. Weigh a recipe out once, in grams, and that one set of numbers feeds the Nutrition Facts panel and the cost per serving. The burger cost calculation guide walks the costing half of that work, and the food cost percentage guide shows how a per-serving cost becomes a menu price at your target percentage.

The connection runs through your inventory too. Stale inventory counts give the costing side and the nutrition side the same old numbers, so the par level guide matters for both.

What You Can Do This Week

  1. Count units for each packaged product you sold in the last 12 months.
  2. Compare each count to the thresholds: under 100 employees and under 100,000 units per product keeps the exemption path open, and under 10 employees and 10,000 units means no notice at all.
  3. Decide panel versus exemption for each product, and write the decision down.
  4. If a product needs a panel, run it through the full pre-print checklist before you order labels.

The Bottom Line

The panel rules reward deciding early. Count your units, pick the exemption or the panel for each product, and where the panel is required, build it from weighed recipe data in software that applies the rounding rules, then check format, serving size, and the 15 entries before artwork leaves. The exemption paperwork takes an afternoon. A label reprint costs as much as the first run.

FAQ

Do food trucks need a nutrition facts panel?

Only for packaged items, and only above the exemption thresholds. Plated food served from the window carries no panel requirement. A bottled sauce or a bagged snack you sell from the truck is a packaged product, and its units count against the 100,000-unit threshold separately from every other product.

What is the small business exemption for nutrition labels?

A provision in 21 CFR 101.9(j)(18) that excuses qualifying low-volume products from carrying the panel. It takes fewer than 100 average full-time equivalent employees, fewer than 100,000 units of the product sold in the United States in a 12-month period, and no nutrition information or claims anywhere on the label or in advertising. File the notice before the 12-month period it covers through the FDA's online exemption portal, unless you are under 10 employees and 10,000 units, in which case no notice is required.

Can I use a nutrition label maker instead of lab testing?

Usually. Database-based generators cover recipes built from packaged ingredients with supplier spec sheets. Recipes with major cooking losses or frying change weight and nutrient concentration, and software without your yield data will print wrong values. Laboratory analysis is the accurate route for those, at a cost that usually reserves it for top sellers.

What size does the nutrition facts panel need to be?

Big enough for the format rules that apply to your package. The standard vertical panel needs continuous vertical space. Packages with 40 or fewer square inches of label space may use a tabular display, and packages under 12 square inches may use a single-line linear display. Packages holding roughly two to three times the reference amount need dual columns. Type minimums scale with the panel, and undersized type makes a label noncompliant regardless of the data in it.

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