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Frozen Food Labeling Requirements

Quick answer

Frozen food labeling requirements are mostly the same as for any packaged food: a name, the net quantity, an ingredient list, allergens, your name and address, and Nutrition Facts for the food as packaged. Freezing adds a short list of its own: volume is measured at the frozen temperature, "fresh frozen" has a legal meaning, frozen dinners have a set name, and "Keep frozen" is required only in specific cases.

Frozen food labeling requirements on three freezer products: a frozen cheese pizza box, a pint of ice cream and a bag of fresh frozen peas, each with its net quantity and Nutrition Facts
Pizza, ice cream and vegetables: one freezer, different rules
01

Rules that apply because the food is frozen

RuleWhat it means for your labelSource
Volume of a frozen foodA food sold and eaten frozen, like ice cream, states its fluid measure at the frozen temperature21 CFR 101.7(b)(2)(i)
"Fresh frozen" and "frozen fresh"Only for food frozen quickly while still fresh, meaning recently harvested. Blanching first is allowed21 CFR 101.95(b)
"Fresh" on its ownMay not suggest that a frozen food is unprocessed: fresh means never frozen21 CFR 101.95(a)
Frozen dinnersA set name with the components listed, and Keep Frozen when the word frozen is left out21 CFR 102.26
Nutrition FactsFor the food as packaged. An extra "as prepared" column is allowed21 CFR 101.9(e)
Frozen dough, batter or pastaThe reference amount is what it takes to make the reference amount of the finished food21 CFR 101.12(b), (c)

"Quickly frozen" has a definition too: a system like blast freezing that freezes the food to the center fast enough that virtually no deterioration takes place.

21 CFR 101.7 · 101.9(e) · 101.12 · 101.95 · 102.26Net quantity of frozen food, forms of the food on the panel, reference amounts, fresh and fresh frozen, and frozen dinners.
02

When "Keep frozen" is required

There is no general FDA rule that every frozen food must say Keep Frozen. The line is required in these cases:

  • FDA frozen dinners that leave the word "frozen" out of their name: "Keep Frozen" or similar, prominent on the front, at least 1/16 inch tall on a front panel of 5 square inches or less and 1/8 inch on anything larger
  • USDA-inspected meat products that need special handling: "Keep Frozen" or "Keep Refrigerated" on the front. Products shipped frozen and thawed for display add "Previously Handled Frozen for Your Protection, Refreeze or Keep Refrigerated"
  • Vacuum-packed or other reduced oxygen packaged raw fish that relies on freezing for safety: FDA's import alert for these products accepts packages labeled to keep frozen and to thaw under refrigeration, for example "Important, keep frozen until used, thaw under refrigeration immediately before use", or to remove the fish from the package before thawing

For other FDA foods, like frozen vegetables, fruit, pizza or desserts, Keep Frozen is your choice. It is still worth printing: one short line tells every store and shopper how to hold your product.

21 CFR 102.26(b)(1) · 102.5(b)(2)(i) · 9 CFR 317.2(k) · FDA Import Alert 16-125The frozen dinner name and its type size, USDA's handling statement for meat products, and FDA's labeling expectation for frozen reduced oxygen packaged fish.
03

Frozen dinners: the name FDA sets

  • A frozen dinner has at least three components, one of them a significant source of protein. Each is meat, poultry, fish, cheese, eggs, vegetables, fruit, potatoes, rice or another cereal product (bread and rolls do not count)
  • The name is "frozen heat and serve dinner". "Heat and serve" is optional, and the main ingredient may go before "dinner": "Frozen salmon dinner"
  • Right after or below it, the components in order by weight: "Containing salmon, rice and green beans". Extras like a roll or a dessert follow
  • A serving suggestion picture that shows food not in the package needs a statement on the front that those foods are not included

A dinner with enough meat or poultry to need USDA inspection follows USDA's labeling rules instead. If you are unsure which agency covers your recipe, ask USDA's Food Safety and Inspection Service before you print.

21 CFR 102.26What a frozen heat and serve dinner is and how its common or usual name is built.
04

Serving sizes for frozen products

Frozen productReference amount
Ice cream, frozen yogurt, sherbet, pops and novelties2/3 cup, including coatings and wafers
Plain fish and shellfish, no sauce85 g cooked, 110 g uncooked
Fish or shellfish entrees with sauce140 g cooked
Dumplings, potstickers, egg rolls, mini pizzas85 g, plus 35 g with gravy or sauce
Frozen French fries, unprepared85 g
Pizza140 g, labeled as a fraction of the pizza
Frozen dough, batter or pastaThe amount that makes the finished reference amount
21 CFR 101.12(b), (c) · 101.9(b)(2)(ii)FDA's reference amounts table, unprepared products, and fractional slices for large units like pizza.
Frozen Food Label Design →
05

Example: frozen cheese pizza, 12 inch

Ingredients: Enriched bread flour (wheat flour, niacin, reduced iron, thiamine mononitrate, riboflavin, folic acid), mozzarella cheese (pasteurized milk, cheese culture, salt, enzymes), tomato sauce (tomato puree, salt, spices), water, olive oil, yeast, salt, oregano. Contains: Milk, Wheat.

  • Pizza is a large unit people divide, so the serving is the fraction closest to the 140 g reference amount: 1/4 pizza (138g)
  • The numbers are for the pizza as packaged, frozen and unbaked. Print baking directions and you may add an as-prepared column
  • Net weight on the front, in ounces with pounds and grams: NET WT 19.5 OZ (1 LB 3.5 OZ) 553g
  • Sodium is 670 mg per serving, 29% of the Daily Value. Mozzarella, sauce and salt add up
21 CFR 101.9(b)(2)(ii) · 101.9(e) · 101.7(d), (j)Fractional slices, nutrition for the form as packaged, and net weight with decimal fractions of an ounce.
Nutrition Facts
4 servings per container
Serving size1/4 pizza (138g)
Amount per serving
Calories280
% Daily Value*
Total Fat 11g14%
Saturated Fat 4.5g23%
Trans Fat 0g
Cholesterol 25mg8%
Sodium 670mg29%
Total Carbohydrate 31g11%
Dietary Fiber 2g7%
Total Sugars 2g
Includes 0g Added Sugars0%
Protein 14g
Vitamin D 0.1mcg0%
Calcium 260mg20%
Iron 2mg10%
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: frozen cheese pizza, 4 servings
06

Ice cream: a name with a recipe

  • "Ice cream" is a standardized name: at least 10% milkfat, at least 1.6 pounds of total solids per gallon, and a weight of at least 4.5 pounds per gallon
  • A pint declares its volume at the frozen temperature, in fluid ounces with the larger unit and the metric amount: "16 FL OZ (1 PT) 473 mL"
  • Serving size is 2/3 cup. A bar, sandwich or cone sold on its own is labeled by the piece
21 CFR 135.110(a) · 101.7(b)(2)(i), (j) · 101.12(b)The ice cream standard, fluid measure at the frozen temperature with pints, and the frozen dessert reference amount.
07

Small frozen food businesses and Nutrition Facts

  • Selling straight to consumers at markets or online: exempt with $500,000 or less in sales to consumers a year, or $50,000 or less in food sales to consumers
  • Selling through stores: the low-volume exemption covers fewer than 100 full-time equivalent employees and fewer than 100,000 units of the product a year, with a notice to FDA unless you are under 10 employees and 10,000 units and do not import
  • Both end the moment you make a nutrition claim or share nutrition information
21 CFR 101.9(j)(1), (j)(18)The small retailer and low-volume exemptions.
Do I Need a Nutrition Label? →
08

Frozen food label checklist

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Questions

Questions

No. FDA requires it on frozen dinners that leave the word frozen out of the name, and expects it on frozen reduced oxygen packaged fish. USDA requires a handling statement on meat products that need one. For other FDA foods it is optional, and still a good idea.

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