REGAFFAIRS AI
GUIDE · 2026-10-08 · 7 min

FDA nutrition facts label rules, type sizes and exemptions

The FDA Nutrition Facts label is required on most packaged US food under 21 CFR 101.9. See the 15 entries, type sizes, formats and exemptions.

FDA nutrition facts label requirements under 21 CFR 101.9

The FDA Nutrition Facts label is the nutrition panel required on most packaged food sold in the US, and its rules sit in 21 CFR 101.9. Nutrients are listed per serving, in a fixed order, with set type sizes.

The legal basis is the Nutrition Labeling and Education Act of November 8, 1990. The current design comes from FDA's May 27, 2016 final rule, published alongside a serving size rule the same day. A 2018 rule pushed compliance back. Manufacturers with $10 million or more in annual sales had to switch by January 1, 2020. Those with less than $10 million in annual food sales had until January 1, 2021. Most single-ingredient sugars such as honey and maple syrup, plus certain cranberry products, got until July 1, 2021 (FDA). "Calories from Fat" is no longer part of the panel. Vitamins A and C are no longer mandatory unless added or claimed.

Mandatory nutrients and their order

Under 101.9(c), a standard adult panel declares these 15 entries per serving, in this order:

  1. Calories
  2. Total fat
  3. Saturated fat
  4. Trans fat
  5. Cholesterol
  6. Sodium
  7. Total carbohydrate
  8. Dietary fiber
  9. Total sugars
  10. Added sugars, shown as "Includes X g Added Sugars"
  11. Protein
  12. Vitamin D
  13. Calcium
  14. Iron
  15. Potassium

The last four are declared by weight and as a %DV. Other vitamins and minerals become mandatory when you add them as a nutrient supplement or make a claim about them. Only nutrients authorized by 101.9(c) may appear inside the panel.

Some lines can be omitted below specific thresholds, with a "Not a significant source of ..." statement. For example, cholesterol under 2 mg qualifies if there's no fat or cholesterol claim. Check each nutrient's conditions in 101.9(c) before removing its line.

Polyunsaturated and monounsaturated fat, sugar alcohol and fluoride are generally voluntary. Declaring either of those fats makes the other mandatory. A fatty acid or cholesterol claim can require them too. Check 101.9(c) before you omit a line.

Two rounding examples: calories under 5 may be shown as 0, then go to the nearest 5 up to 50 and the nearest 10 above that. Sodium under 5 mg is 0, then nearest 5 mg up to 140 mg, then nearest 10 mg. Use the nutrient-specific rounding rules in 101.9(c), including those for vitamin and mineral %DVs.

The footnote text is fixed by 101.9(d)(9): "*The % Daily Value 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." Foods for children 1 through 3 say "1,000 calories" instead. A calorie-free type term lets you omit the footnote.

Nutrition facts label format and font sizes

The format rules sit in 101.9(d). The panel is set off in a hairline box, printed in all black or one color, on a white or other neutral contrasting background whenever practical. FDA "strongly recommends" the graphic specifications in Appendix B to part 101.

There is no required nutrition facts label font. The rule asks for "a single easy-to-read type style" in upper and lower case, with at least 1 point of leading. Nutrient lines and vitamin and mineral lines need at least 4 points of leading. Letters should not touch. FDA's example label PDF uses Helvetica and notes "bold font is Helvetica Black; text not bolded is Helvetica Regular". That note is not a requirement.

Minimum type sizes for the standard vertical format, from (d)(1)(iii), (d)(2) and (d)(3):

ElementStandard minimumSmaller option
"Nutrition Facts"No fixed size; no smaller than any other print on the label except the calorie numberNone
"__ servings per container"10 pt9 pt in small-package tabular and linear displays
"Serving size" (bold)10 pt9 pt in tabular and small-package displays; 8 pt on any package if it will not fit
"Calories" (bold)16 pt10 pt in tabular and small-package displays
Calorie number (bold)22 pt14 pt in small-package tabular and linear displays
Nutrient and vitamin/mineral lines8 ptSee the under-12-square-inch exception below
"Amount per serving", "% Daily Value*", footnote6 ptNone

The reduced sizes apply only in the format named in the table. Any package may use 8 pt for "Serving size" if 10 pt will not fit. A big box can't shrink the rest of the type just to free up space.

Bold is reserved for "Nutrition Facts", "Serving size", "Amount per serving" and "% Daily Value*", the non-indented nutrient names (Calories, Total Fat, Cholesterol, Sodium, Total Carbohydrate, Protein) and the %DV numbers. Reverse printing can't be used for highlighting, and nothing else may be highlighted. Hairline rules in 101.9(d)(1) separate "Nutrition Facts" from servings per container, and they separate each nutrient line from the next. A bar in (d)(4) separates serving size from "Amount per serving". A bar in (d)(6) separates calories from the % Daily Value heading. (d)(9) puts a bar between the vitamins and minerals and the footnote. You may write "Percent Daily Value", "Percent DV" or "% DV" instead of "% Daily Value".

FDA's example label shows 7 pt, 3 pt and 1/4 pt rules with a 1/2 pt box. Check Appendix B to part 101 before you lock in those weights.

Alternative formats

The regulation allows several layouts besides the standard vertical panel:

  • Tabular display, when the package lacks about 3 inches of vertical space.
  • Aggregate display, for variety packs.
  • Dual columns, for example "as packaged" and "as prepared".
  • Dual columns per serving and per package, generally required for individually sold packages holding 200% to 300% of the reference amount. Check 101.9(b) for exceptions. A package under 200% sold individually counts as one serving.
  • A simplified format, when 8 or more core nutrients are present only in insignificant amounts (6 or more for foods for infants and children 1 to 3).

Small packages get their own rules in (j)(13). With less than 12 square inches of labeling surface, a package may omit the panel if there are no nutrition claims or other nutrition information in labeling or advertising. It must give an address or phone number for nutrition information. If nutrition labeling is provided, this exception allows 6 pt type or all capitals at least 1/16 inch high. Packages with 40 square inches or less of labeling surface may use tabular format, or linear if tabular won't fit. They can also use abbreviations like "Serv size", "Sat fat", "Cholest" and "Total carb", and shorten the footnote to "% DV = % Daily Value". Packages over 40 square inches with no room on the information panel may use any panel consumers can readily see.

Exemptions, including for small businesses

Most exemptions in 101.9(j) are lost the moment a nutrition claim or other nutrition information appears on the label, in labeling or in advertising, even a single "low fat" claim. The two small-business tests are not the same:

  • (j)(1) covers direct-to-consumer sellers such as retailers. It needs annual gross sales to consumers of no more than $500,000, or annual food sales to consumers of no more than $50,000, based on the most recent 2-year average. No notice is needed.
  • (j)(18) covers low-volume products, one product at a time. The firm must average fewer than 100 full-time equivalent employees and sell fewer than 100,000 units of that product in the US over the past 12 months. A notice goes to FDA's Office of Nutrition and Food Labeling before the exemption period. A non-importer with fewer than 10 FTEs selling fewer than 10,000 units a year doesn't need to file. FTEs are total paid hours divided by 2,080, affiliates included. Go over the limits and you get 18 months to comply.

Other exemptions in 101.9(j) cover restaurant and food-service food, ready-to-eat food made and sold in a retail store, and foods with insignificant amounts of all nutrients such as coffee, tea and spices. Bulk food for further manufacture is also exempt. Raw fruits, vegetables and fish follow voluntary guidelines in 101.45. Dietary supplements use the Supplement Facts label under 101.36, and infant formula and medical foods have their own rules.

Templates, generators and nutrition label software

There is no blank nutrition facts label template from FDA. Its industry resources page says: "FDA has not provided label templates in the past and we do not plan to do so now." The page says the private sector is equipped to provide them. FDA's reference graphics are PDF 1 and PDF 2, not templates. FDA does not endorse label software. If you use a generator or nutrition labeling software to create a nutrition facts label from a recipe, compare the panel with 101.9(d) and Appendix B: nutrient order, type sizes, bold, bars and footnote wording.

Front-of-package nutrition labeling

FDA proposed a front-of-package "Nutrition Info box" on January 16, 2025. Comments closed July 15, 2025, and it was not finalized or withdrawn as of October 8, 2026.

FDA's regulations-under-development page lists a December 2026 publication goal for a final rule. That is not a compliance date, and the proposal does not require the box. The separate "healthy" claim rule, with a compliance date of February 25, 2028, does not change this panel.

You can ask RegAffairs AI follow-up questions on its cited answer on Nutrition Facts requirements, type sizes and small-business exemptions.