Prepared food label requirements by sales channel
| How you sell | Nutrition Facts | Why |
|---|---|---|
| Meals packed ahead and sold through gyms, cafes or grocery stores | Yes, unless the low-volume exemption fits | The food is offered for sale outside your own establishment |
| Grab-and-go meals made and sold only in your own shop | Not required, if you make no nutrition claims | Prepared on site and not sold anywhere else |
| Meals served in your restaurant or cafe | Not required, if you make no nutrition claims | Restaurant food is exempt |
| You sell directly to consumers with small total sales | Not required, if you make no nutrition claims | The small business exemption |
| Any of the above, with calories or macros on the label, website, menu or social posts | Yes | Nutrition information ends every exemption |
| A chain with 20 or more locations under the same name | Calories on menus and menu boards instead | The menu labeling rule |
When a meal prep business can skip Nutrition Facts
- Small business: you sell directly to consumers, and your total sales to consumers are no more than $500,000 a year or your food sales to consumers no more than $50,000. FDA uses the average of the last two years; a new business uses a reasonable estimate
- Restaurants and food service: meals served where food is eaten right away. FDA's list of examples includes delis with seating, cafeterias, and food delivery systems that bring ready-to-eat food to homes or offices
- Made and sold on site: ready-to-eat meals prepared mainly in your retail establishment and not offered for sale outside it, like a deli case or salad bar
- Low volume: fewer than 100 full-time equivalent employees and fewer than 100,000 units of the product sold in the US in 12 months, with a notice filed with FDA. Below 10 employees and 10,000 units a year, no notice is needed unless you import
All four share one condition: the food bears no nutrition claims or other nutrition information in any context, on the label, in labeling or in advertising. Calories and macros on your website, menu or social posts are exactly that. Once you publish them, each meal needs a complete Nutrition Facts panel that matches.
The on-site exemption is lost the day a gym, coffee shop or corner store starts selling your meals, because the food is now offered for sale outside your establishment. Weekly delivery is a gray area: the rule names delivery of ready-to-eat food as an example, but it does not say how long the food may sit in a customer's fridge. If you are unsure, label.
Meal prep label requirements for packed meals
- A name that says what the meal is: "Lemon herb salmon with rice and green beans", not a menu number
- The net weight of the food, without the container, in ounces and grams
- One ingredient list for the whole meal, heaviest first, with the sub-ingredients of anything bought in, like sauces and cheese
- The allergens by name, with the species of fish or shellfish and the type of tree nut: "Contains: Salmon, milk"
- Your business name with city, state and ZIP
- Nutrition Facts, unless one of the exemptions above fits
Serving size is simple for single meals. A meal or main dish in a single-serving container is labeled as one serving: the entire contents. A family tray that is meant to be shared uses the FDA reference amount for that type of food, so it gets several servings.
Allergen labels: packed ahead vs. made to order
FDA's allergen labeling law applies to retail and food-service businesses that package, label and offer food. It does not apply to food placed in a wrapper or container after a customer orders it at the point of purchase, such as a box for a sandwich.
- Meals you pack ahead for your fridge, a gym or a store: allergen statement required
- A bowl you build and box when the customer orders at the counter: the FALCPA labeling rule does not apply
- Either way, customers with allergies will ask. Keep an allergen sheet for every recipe on your menu
Chicken, beef and pork meals: check USDA first
FDA covers most meal prep, but meat and poultry belong to USDA. A food made wholly or partly from the meat of cattle, sheep, swine or goats is a meat food product under USDA's definition, unless USDA exempts it. A consumer-packed food stays outside USDA's poultry rules only with less than 2% cooked poultry meat, among other conditions. A chicken and rice bowl is far above that.
Our tool makes FDA Nutrition Facts. For meals built around meat or poultry, check USDA's Food Safety and Inspection Service rules for your label and your kitchen before you print. Plant-based, egg, cheese and most seafood meals are FDA foods (catfish is the USDA exception).
