FDA tea labeling requirements by product
| Product | Net quantity | Ingredient list | Nutrition Facts |
|---|---|---|---|
| Loose leaf black, green, white or oolong tea | Weight | Not needed, one ingredient | Not needed, if you make no nutrition claims |
| Tea bags of a single tea | Weight of the tea, count optional | Not needed | Not needed, if you make no nutrition claims |
| Herbal, spiced or flavored blends | Weight | Yes, every leaf, herb, spice and flavor by weight | Only exempt if every required nutrient is insignificant and you make no claims |
| Plain unsweetened instant tea | Weight | Not needed if it's only tea | Not needed, if you make no nutrition claims |
| Sweetened iced tea mix | Weight | Yes | Yes, per the amount of powder that makes 12 fl oz |
| Bottled iced tea, sweet tea by the jug | Fluid ounces and mL | Yes | Yes, unless you qualify for an exemption |
FDA's exemption covers foods in which every required nutrient can be declared as zero, or as "less than 1 gram" for carbohydrate, fiber and protein. Its own examples include tea leaves and plain unsweetened instant tea. A nutrition claim such as "zero calories" anywhere on the box or in your ads ends the exemption.
What goes on the box or pouch
- The name of the tea on the front: "Green tea", "Earl Grey black tea", "Rooibos herbal blend"
- The net weight of the tea itself, without wrappers or other packing material. Weigh the tea, not the box or the envelopes
- Count plus weight is common for bags and sachets: "18 PYRAMID SACHETS, NET WT 1.27 OZ (36g)"
- The net quantity sits in the bottom 30% of the front panel, in ounces and grams
- Your business name, city, state and ZIP. If a co-packer fills your bags, qualify your name: "Packed for" or "Distributed by"
- No required text smaller than 1/16 inch
Blends and flavored teas
A blend lists every ingredient by its common name, heaviest first: tea, dried fruit, flowers, spices, then flavor. On the front, the flavor you name decides the wording:
| What's in the bag | How the name reads |
|---|---|
| Real peach pieces that carry the taste | Peach green tea |
| Peach pieces plus natural flavor from other sources that boosts the peach taste | Peach green tea with other natural flavor |
| No peach, or too little to taste, plus natural peach flavor | Peach flavored green tea, or natural peach flavored green tea |
| Natural flavor that tastes like peach but is not made from peach | Artificially flavored peach green tea, or named after the source of the flavor |
| Artificial peach flavor | Artificial peach green tea, or artificially flavored peach green tea |
The flavor name must be at least half as tall as the letters in the name of the tea, and words like "flavored" or "artificial" at least half as tall as the flavor name. Ask your flavor house for paperwork: FDA requires a supplier who sells a flavor as containing no artificial flavor to certify that in writing.
Sweet tea and bottled tea drinks
The FDA reference amount for flavored and sweetened tea is 360 mL (12 fl oz) as prepared. Your bottle size decides how the label looks:
| Bottle | Share of 12 fl oz | Label |
|---|---|---|
| 16 fl oz | 133% | One serving: the whole bottle |
| 20 fl oz | 167% | One serving; an extra column per 12 fl oz is optional |
| 24 to 36 fl oz | 200% to 300% | Dual column: per 12 fl oz and per bottle |
| Half gallon (64 fl oz) | 533% | Standard label, about 5 servings |
| Gallon (128 fl oz) | 1,067% | Standard label, about 11 servings |
Our gallon of sweet tea with lemon: 15 cups brewed tea, 1 cup sugar, 1/2 cup lemon juice.
Ingredients: Brewed tea (water, tea), sugar, lemon juice.
- All 19 g of sugars per serving are added sugars, 38% of the Daily Value
- Brewed tea is not tea leaves: in our tool, 12 fl oz of plain brewed black tea (USDA data) already shows 10 mg sodium and 130 mg potassium. Check the numbers before you count on the exemption for a bottled unsweetened tea
- The liquid serving is declared in mL. Our tool does this with the Liquid box ticked
Tea drinks with lemon or fruit: the percent juice rule
A tea drink that names a fruit, shows a fruit, or looks and tastes like it contains juice falls under FDA's percent juice rule:
- With juice in it: declare the total juice, such as "Contains 5% lemon juice", as a whole number not above the actual amount. Under 1%: "less than 1% juice"
- The statement goes near the top of the information panel, in bold, with nothing above it except the brand, product name, logo or barcode
- No declaration is needed for minor amounts of juice used for flavor when the name uses "flavor" or "flavored", the label shows no "juice" outside the ingredient list, no explicit picture of the fruit (such as juice dripping from a lemon), and the drink doesn't resemble juice
- A fruit name or picture with no juice at all, and no flavor exemption: "contains 0% juice" or "no lemon juice"
Claims, health wording and supplement teas
- Nutrient claims like "zero calories" or "sugar free" follow FDA's claim definitions and bring back Nutrition Facts for plain tea
- Anything about a disease is a health claim and must fit a claim FDA has authorized or allowed. FDA's list of qualified health claims includes one on green tea and cancer, with set wording and conditions. Check it before you print
- "Organic" is a USDA term with its own certification rules
- A tea labeled as a dietary supplement follows Supplement Facts rules. By law, a dietary supplement may not be represented for use as a conventional food, so how you market the tea matters
