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FDA Ingredient Labeling Requirements

Quick answer

FDA ingredient labeling requirements say a food made from two or more ingredients must list each one by its common or usual name, in descending order of predominance by weight (21 CFR 101.4). The list goes on the front panel or the information panel, in letters at least 1/16 inch tall. Ingredients that have their own ingredients show them in parentheses, and spices, flavors, colors and preservatives follow special naming rules.

FDA ingredient labeling requirements shown on a cookie package: the ingredient list in order by weight, sub-ingredients in parentheses and a Contains statement below it
One list, heaviest ingredient first
01

The basic food ingredient labeling requirements

  • Order: heaviest ingredient first, lightest last, by weight, not by volume
  • Names: the common or usual name, and a specific one. "Canola oil", not "oil"
  • Water you add is an ingredient and is listed by weight like any other
  • On labels, "sugar" means sucrose from sugar cane or sugar beets. Other sweeteners use their own names
  • Place: on the principal display panel or the information panel
  • Size: no letter smaller than 1/16 inch
  • A food with a single ingredient, like honey or plain coffee beans, needs no ingredient list
Principal Display Panel →
21 CFR 101.4(a)(1), (b), (b)(20) · 101.2(b), (c) · 21 U.S.C. 343(i)Order by weight and specific names, the meaning of sugar, placement and type size, and the law that requires a list for foods made from two or more ingredients.
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Ingredients that have their own ingredients

Chocolate chips, butter, enriched flour and other compound ingredients can be declared two ways:

MethodHow it looksWhen to use it
Name with parenthesesSemisweet chocolate chips (sugar, chocolate, cocoa butter, milkfat, soy lecithin, vanilla extract)Most common. Sub-ingredients in their own order by weight
Break it outEach component (sugar, chocolate, cocoa butter...) merged into the main list at its total weightWhen the same components already appear elsewhere in your list
  • Fats and oils are named one by one. A blend may be shown as "blend of vegetable oils (soybean oil, palm oil)"
  • Leavening, yeast nutrients, dough conditioners and firming agents may use a group name with the parts in parentheses: "leavening (baking soda, monocalcium phosphate)"
  • Some dairy and egg forms may use a short name: dried whey as "whey", liquid whole eggs as "eggs"
21 CFR 101.4(b)(2) to (b)(19)The two methods for compound ingredients, fats and oils, leavening and similar groups, and the short names for dairy and egg forms.
03

The 2 percent rule

Ingredients at 2% or less of the food by weight may leave the strict order. List them at the end after a phrase like "Contains 2% or less of: salt, baking soda, vanilla extract".

  • The threshold may be 2%, 1.5%, 1% or 0.5%
  • No ingredient after the phrase may be above the stated threshold
  • If you show an ingredient's percentage, it goes in parentheses after its name, rounded to the nearest 1%
21 CFR 101.4(a)(2), (e)The 2% rule and percentage declarations.
04

Spices, flavors, colors and preservatives

Ingredient typeHow to name itExample
Spices"Spice", or the name of the spiceSpices, or cinnamon
Dried vegetables used for flavorBy name. These count as food, not "spice"Garlic powder, onion powder, celery powder
Flavors"Natural flavor" or "artificial flavor"Natural flavor
Salt and MSGAlways by nameSalt, monosodium glutamate
Certified colorsBy name, "FD&C" and "No." may be dropped; lakes say "Lake"Red 40, Blue 1 Lake
Colors exempt from certification"Artificial color", "color added", or "colored with" plus the nameColor added
Chemical preservativesName plus what it doesAscorbic acid (to promote color retention)
  • A protein hydrolysate used for flavor can't hide behind "natural flavor". It needs its own name
  • If a flavor, color or spice blend carries one of the 9 major allergens, the allergen must still be declared
21 CFR 101.22(h), (j), (k) · 21 U.S.C. 343(w)Naming rules for spices, flavors, salt, MSG, protein hydrolysates, colors and preservatives, and allergens in flavors and colors.
05

What you can leave off the list

Incidental additives present at insignificant levels with no function in the finished food are exempt:

  • Carryover: a substance that worked in an ingredient but does nothing in your food
  • Processing aids that are removed before packaging, or that become normal parts of the food
  • Substances that migrate from equipment or packaging

Two limits: sulfites at 10 ppm or more in the finished food must be listed, and an allergen is never exempt as an incidental additive.

21 CFR 101.100(a)(3), (a)(4) · 21 U.S.C. 343(w)The incidental additive exemption, the 10 ppm sulfite rule, and allergen declaration for incidental additives.
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Example: a chocolate chip cookie

Ingredients: Semisweet chocolate chips (sugar, chocolate, cocoa butter, milkfat, soy lecithin, vanilla extract), enriched bleached flour (wheat flour, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), butter (cream, salt), brown sugar, sugar, eggs, baking soda, vanilla extract (vanilla bean extractives in water, alcohol), salt. Contains: Milk, Egg, Wheat, Soy.

  • Chocolate chips come first: 2 cups of chips weigh more than 2 1/4 cups of flour
  • Brown sugar and sugar are separate ingredients, so each gets its own spot. "Sugar" is the white sucrose
  • Compound ingredients show their parts in parentheses
  • Soy hides in the soy lecithin of the chips, and milk in "butter (cream, salt)". The Contains line names both

Our tool writes this list from your recipe: it works out the weight of every ingredient, sorts by weight, adds the sub-ingredients and builds the Contains line.

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Ingredient label requirements checklist

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Questions

Questions

By weight. A cup of chocolate chips weighs more than a cup of flour, so measuring cups can put your list in the wrong order. Weigh each ingredient, or let our tool convert your cups and spoons to weights. Start a label →

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