FDA coffee labeling requirements by product
| Product | Ingredient list | Nutrition Facts |
|---|---|---|
| Whole bean or ground coffee, single origin or blend | Not needed, one ingredient | Not needed, if you make no nutrition claims |
| Plain unsweetened instant coffee | Not needed if it is only coffee | Not needed, if you make no nutrition claims |
| Flavored beans or grounds | Yes: "Coffee, natural flavor" | Not needed while every nutrient still rounds to zero and you make no claims |
| Coffee pods and single-serve cups | Same as the coffee inside | Same as the coffee inside |
| Bottled cold brew or latte with milk, sugar or syrup | Yes | Yes, unless you qualify for an exemption |
The Nutrition Facts exemption covers foods with insignificant amounts of every required nutrient: an amount that can be declared as zero, or "less than 1 gram" for carbohydrate, fiber and protein. FDA names whole and ground coffee beans and plain unsweetened instant coffee as examples. A nutrition claim on the bag, like "zero calories", cancels the exemption.
Coffee bag label requirements
- A name on the front that says what it is: "Whole bean coffee", "Ground coffee", "Medium roast ground coffee". Roast level and origin can go with it
- Net weight on the front, in the bottom 30% of the panel, in ounces with grams: "NET WT 12 OZ (340g)". From 1 lb up, add pounds: "NET WT 16 OZ (1 LB) 454g"
- Your business name and address with city, state and ZIP. If a co-roaster packs for you, qualify it: "Distributed by" or "Roasted for" (any wording that states the facts)
- Everything in letters at least 1/16 inch tall
Origin, roast and quality words
There is no FDA standard for words like "single origin", "100% Arabica" or "Colombian". They fall under the general rule: a food label must not be false or misleading in any particular. Keep the paperwork from your green coffee importer that backs up each one.
- "Organic" is a USDA term with its own certification rules
- "Gluten-free" on coffee must meet FDA's gluten-free definition, like on any food
- Nutrient claims like "zero calories" or "sugar free" follow FDA's claim definitions and bring back Nutrition Facts
Flavored coffee: names, flavors and allergens
- In the ingredient list, flavor is "natural flavor", "artificial flavor" or both
- Once the front names a flavor, such as "Hazelnut" or "Vanilla", it is the characterizing flavor and the name must carry it in letters at least half the height of the product name
- Artificial flavor that simulates the named flavor means "artificial" or "artificially flavored" next to it: "Artificially flavored hazelnut coffee"
- A natural flavor that is not from the named food changes the wording too. Ask your flavor house for a written statement of what the flavor is
Allergens are the trap. A hazelnut or almond flavor may or may not contain nut protein. If it does, your label must name the nut, for example "Contains: hazelnuts", even though the ingredient list only says "natural flavor". Get the allergen statement from your flavor supplier in writing.
Cold brew and bottled coffee drinks
A coffee drink with milk, plant milk, sugar or syrup has real nutrients, so it needs Nutrition Facts unless you qualify for a small business exemption. The FDA reference amount for flavored and sweetened coffee is 12 fl oz (360 mL). A 12 fl oz bottle is one serving.
Ingredients: Brewed coffee (water, coffee), almond milk (filtered water, almonds, calcium carbonate, sea salt, sunflower lecithin, gellan gum), maple syrup. Contains: Almonds.
- The almond milk makes this a tree nut product. The Contains line names almonds, not just tree nuts
- Maple syrup counts as added sugars: 12g of the 13g total sugars
- Shelf-stable cold brew in sealed cans or bottles is usually a low-acid food (pH above 4.6). That brings FDA's low-acid canned food processing rules. Many small brewers sell refrigerated instead