7 min read

FDA Tea Labeling Requirements

Quick answer

FDA tea labeling requirements depend on the form you sell. Loose leaf tea and tea bags need a name, the net weight of the tea and your name and address, plus an ingredient list once you blend in anything else. Plain tea leaves skip Nutrition Facts: FDA names them as a food with insignificant nutrients. Sweet tea, bottled tea drinks and sweetened mixes need a Nutrition Facts panel based on 12 fl oz (360 mL) as prepared, unless an exemption applies.

FDA tea labeling requirements on three products: a pouch of loose leaf green tea, a box of pyramid tea sachets and a gallon jug of sweet tea with lemon carrying a Nutrition Facts panel
Leaves, bags and drinks follow different rules
01

FDA tea labeling requirements by product

ProductNet quantityIngredient listNutrition Facts
Loose leaf black, green, white or oolong teaWeightNot needed, one ingredientNot needed, if you make no nutrition claims
Tea bags of a single teaWeight of the tea, count optionalNot neededNot needed, if you make no nutrition claims
Herbal, spiced or flavored blendsWeightYes, every leaf, herb, spice and flavor by weightOnly exempt if every required nutrient is insignificant and you make no claims
Plain unsweetened instant teaWeightNot needed if it's only teaNot needed, if you make no nutrition claims
Sweetened iced tea mixWeightYesYes, per the amount of powder that makes 12 fl oz
Bottled iced tea, sweet tea by the jugFluid ounces and mLYesYes, 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.

21 CFR 101.9(j)(4) · 101.4(a)(1) · 101.7(a) · 101.12(b), Table 2The insignificant-nutrients exemption naming tea, ingredient order, net quantity by weight or fluid measure, and the 360 mL prepared reference amount for flavored and sweetened tea.
02

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
Co-Packer →
21 CFR 101.3 · 101.5(c), (d) · 101.7(f), (g) · 101.2(c) · 15 U.S.C. 1453(a)(2)Statement of identity, name and place of business, net quantity placement and what it excludes, minimum type size, and the customary plus metric units.
Statement of Identity →
03

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 bagHow the name reads
Real peach pieces that carry the tastePeach green tea
Peach pieces plus natural flavor from other sources that boosts the peach tastePeach green tea with other natural flavor
No peach, or too little to taste, plus natural peach flavorPeach flavored green tea, or natural peach flavored green tea
Natural flavor that tastes like peach but is not made from peachArtificially flavored peach green tea, or named after the source of the flavor
Artificial peach flavorArtificial 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.

21 CFR 101.22(i)(1), (i)(2), (i)(4)Characterizing flavor wording, type size, and the supplier's written certification for natural flavors.
04

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:

BottleShare of 12 fl ozLabel
16 fl oz133%One serving: the whole bottle
20 fl oz167%One serving; an extra column per 12 fl oz is optional
24 to 36 fl oz200% 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
Start a label →
21 CFR 101.12(b), Table 2 · 101.9(b)(6), (b)(7), (b)(12)(i) · 101.9(c)(6)(iii)The 360 mL reference amount, single-serving containers, mL serving sizes, dual column labels, and added sugars.
Nutrition Facts
about 11 servings per container
Serving size12 fl oz (360mL)
Amount per serving
Calories80
% Daily Value*
Total Fat 0g0%
Saturated Fat 0g0%
Trans Fat 0g
Cholesterol 0mg0%
Sodium 10mg0%
Total Carbohydrate 21g8%
Dietary Fiber 0g0%
Total Sugars 19g
Includes 19g Added Sugars38%
Protein 0g
Vitamin D 0mcg0%
Calcium 0mg0%
Iron 0.1mg0%
Potassium 140mg2%
*The % Daily Value (DV) 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.
Example: sweet tea with lemon, 1 gallon jug
05

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"
21 CFR 101.30(a) to (e) · 21 U.S.C. 343(i)Which drinks need a percent juice declaration, its wording and placement, and the flavoring exemption.
Juice Label Requirements →
06

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
21 CFR 101.9(j)(4) · 101.13 · FDA, Qualified Health Claims: Letters of Enforcement Discretion · 21 U.S.C. 321(ff)(2) · 7 CFR 205Claims ending the tea exemption, nutrient content claims, FDA's list of qualified health claims, the definition of a dietary supplement, and the USDA organic rules.
Beverage Labeling Requirements →
07

Tea label checklist

0 of 8 checkedSaved on this device
Questions

Questions

Not for plain tea leaves. FDA names tea leaves as a food whose nutrients are all insignificant. Herbal and flavored blends qualify only if every required nutrient can be declared as zero (or less than 1 g for carbs, fiber and protein), and no blend qualifies once you make a nutrition claim.

See your label before you pay anything

Free preview, no account. $29 when you're ready to print.

Start a label