What every olive oil label must have
- A name that is true: "Extra virgin olive oil", "Olive oil", "Olive-pomace oil", or a blend name (see below)
- Net contents in fluid measure, because oil is a liquid: fl oz plus mL, in the bottom 30% of the front label
- Your business name, city, state and ZIP. Bottling bulk oil under your brand? Qualify it: "Bottled for" or "Distributed by"
- Nutrition Facts per 1 tablespoon, unless you qualify for an exemption
- An ingredient list only if the bottle holds two or more ingredients. Plain olive oil needs none
- Country of origin in English on oil imported in its retail bottle
What FDA requires and what USDA defines
| Topic | FDA (mandatory) | USDA (voluntary) |
|---|---|---|
| Definition of olive oil | No standard of identity for olive oil | Grade standards for olive oil and olive-pomace oil, with chemical and taste tests |
| Grade names like extra virgin | Not defined, but any word on the label must be true | Defined per grade, with limits |
| Blends with other oils | A naming rule (21 CFR 102.37) | Not covered |
| USDA grade marks and shield | None | Only on oil packed in a USDA-approved plant and inspected or certified, with labels approved by USDA |
| Nutrition Facts, net contents, address | Required | Not covered |
USDA says it plainly: "the use of the U.S. grade standards is voluntary." It also wrote them to give state and federal agencies a basis for enforcement when oil is mislabeled. And under the FD&C Act, a label that is false or misleading in any particular is misbranded. Calling a refined oil "extra virgin" is a problem whether or not you ever asked USDA to grade it.
Regulation and label definitions used on olive oil
Free fatty acid, measured as oleic acid, is one of the tests behind each USDA grade. Every grade also has to meet the purity and quality tests in the full standard.
| Term | What it means | Source |
|---|---|---|
| U.S. Extra Virgin Olive Oil | Virgin olive oil with excellent flavor and odor (no defects, some fruitiness) and no more than 0.8 g free fatty acid per 100 g | USDA grade |
| U.S. Virgin Olive Oil | Virgin olive oil with reasonably good flavor and odor and no more than 2.0 g free fatty acid per 100 g | USDA grade |
| U.S. Virgin Olive Oil Not Fit for Human Consumption Without Further Processing (lampante) | Poor flavor and odor and more than 2.0 g free fatty acid per 100 g. Meant for refining or non-food use | USDA grade |
| U.S. Olive Oil | A blend of refined olive oil and virgin olive oils, no more than 1.0 g free fatty acid per 100 g | USDA grade |
| U.S. Refined Olive Oil | Refined from virgin olive oils, flavorless and odorless, no more than 0.3 g free fatty acid per 100 g | USDA grade |
| U.S. Olive-Pomace Oil, U.S. Refined Olive-Pomace Oil | Oil taken from the olive pomace left after olive oil is produced, refined, or refined and blended with virgin olive oils. USDA: "Olive-pomace oils shall not be labeled as olive oil" | USDA grade |
| "Light" or "lite" | On oil that isn't at least 50% lower in fat, "light" may only describe a physical or sensory trait, and must say which: "light in color", "light in flavor". The trait word goes right next to "light", same style and color, at least half its size | FDA, 21 CFR 101.56(b)(1), (e) |
| "Pure" | Not one of USDA's grade names. Like any word on the label, it has to be true | 21 U.S.C. 343(a) |
Olive oil blends: FDA's one olive oil rule
A mix of olive oil with another oil may not be sold as "olive oil". FDA requires a descriptive name, such as "canola oil and olive oil". If the label points to the olive oil anywhere outside the ingredient list, with words, an olive branch or a picture of olives, the name must also state the percentage of olive oil.
- Our example: 3 cups canola oil and 1 cup olive oil, with an olive branch on the front. The name reads "Canola oil and olive oil", with "Contains 25% olive oil" on the line below
- For liquids, the percentage is by volume, as a whole number not above the actual amount
- The percentage goes on the line right below the name, in bold, at least 1/8 inch tall on a front panel over 5 square inches (1/16 inch on smaller ones), and at least half the height of the name
- Ingredients: Canola oil, olive oil. The ingredient list is by weight: canola comes first
Monounsaturated fat and heart claims
Olive oil is known for its monounsaturated fat, and that line is optional on the Nutrition Facts. Show monounsaturated fat and you must show polyunsaturated fat too, and the other way around. Make any claim about fatty acids or cholesterol, like "high in monounsaturated fat", and both lines become required.
Heart health wording is a health claim. FDA lists a qualified health claim for monounsaturated fatty acids from olive oil and coronary heart disease among its letters of enforcement discretion. Use it only with the wording and conditions FDA set out, and never improvise your own version.
Imported, bulk and repacked oil
- Oil imported in its retail bottle must be marked with the English name of its country of origin, conspicuously and legibly
- Importing bulk oil to bottle here? The importer certifies to customs that repacking won't hide the origin, or that the new bottle will be marked with the country of origin
- Your own name on the bottle needs a qualifier like "Bottled for" or "Imported by" when someone else made or packed the oil
- Origin words like "Italian" or "California" on the front must be true, like every other word on the label
Flavored and infused olive oils
Add garlic, chili, rosemary or lemon and your bottle becomes a food with two or more ingredients: it needs an ingredient list by weight and a check for allergens, such as sesame in a dipping oil. A flavor named on the front follows FDA's flavor rules: "lemon flavored olive oil" when the taste comes from flavoring rather than real lemon, and "artificial" when the flavor is artificial.