FDA Nutrition Label Requirements: Complete 2026 Guide

Every packaged food product sold in the United States must display a Nutrition Facts panel that complies with 21 CFR 101.9. This regulation specifies exactly which nutrients must be declared, how values must be calculated and rounded, what format the panel must use, and where it must appear on the package.

The 2016 final rule updated the Nutrition Facts panel format significantly — adding Added Sugars and updating Daily Values to reflect current nutritional science. As of 2026, all food manufacturers must use the updated format. The previous format is no longer compliant.

The mandatory nutrients are: Calories, Total Fat, Saturated Fat, Trans Fat, Cholesterol, Sodium, Total Carbohydrate, Dietary Fiber, Total Sugars, Added Sugars, Protein, Vitamin D, Calcium, Iron, and Potassium. Vitamins A and C are no longer mandatory but may be declared voluntarily.

The single most common compliance error in nutrition labeling is incorrect rounding. FDA rounding rules in 21 CFR 101.9(c) are nutrient-specific and use different increment thresholds:

Calories below 5 may be expressed as zero. Between 5 and 50, round to the nearest 5. Above 50, round to the nearest 10. So a product with 47 calories declares 45, while a product with 53 calories declares 50.

Total Fat below 0.5g may be expressed as 0g. Between 0.5g and 5g, round to the nearest 0.5g. Above 5g, round to the nearest 1g. The same rules apply to Saturated Fat and Trans Fat.

Sodium below 5mg may be expressed as 0mg. Between 5mg and 140mg, round to the nearest 5mg. Above 140mg, round to the nearest 10mg.

Cholesterol has a special rule: below 2mg, you may declare either less than 5mg or 0mg. Between 2mg and 5mg, declare less than 5mg. Above 5mg, round to nearest 5mg.

These rules exist because nutrient analysis has inherent variability. Rounding accounts for this variability while preventing misleading precision. A spreadsheet that simply rounds everything to the nearest whole number will produce non-compliant values.

Your serving size is not whatever amount you think people should eat. FDA requires serving sizes to be based on Reference Amounts Customarily Consumed (RACCs) — standardized amounts published in 21 CFR 101.12 that represent how much of a food people typically eat in one sitting.

To determine your serving size: First, identify your product category in the RACC table. The table organizes foods into groups like Bakery Products, Beverages, Cereals, Dairy Products, Desserts, and about 15 other categories. Each category has a reference amount in grams or milliliters.

For example, cookies have a RACC of 30g. If your cookie weighs 28g, the serving size is 1 cookie (28g). If your cookie weighs 45g, the serving size is still 1 cookie (45g) because it falls within the single-serving range (67-200% of RACC). If your cookie weighs 15g, the serving size is 2 cookies (30g) — the number of whole units closest to the RACC.

The household measure must be expressed in common terms: cups, tablespoons, pieces, slices, or fractions thereof. The metric equivalent follows in parentheses. This dual declaration — 1/2 cup (120mL) — is required on every label.

FDA requires declaration of nine major food allergens under FALCPA (2004) and the FASTER Act (2021, which added sesame). The nine allergens are: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.

You have two options for declaring allergens. Option 1: Include allergens parenthetically in the ingredient list — for example, Enriched Flour (Wheat Flour, Niacin, Reduced Iron...). Option 2: Add a separate Contains statement after the ingredient list — Contains: Wheat, Milk, Soy.

Most food manufacturers use both methods. The parenthetical approach satisfies the legal requirement, while the Contains statement provides an easy-to-scan summary for consumers with allergies.

For tree nuts, fish, and crustacean shellfish, you must specify the species. Declare Tree Nuts (Almonds) not just Tree Nuts. Declare Fish (Cod) not just Fish.

Allergen mislabeling is the leading cause of food recalls in the United States. A single missed allergen — especially in a reformulated product where a new ingredient introduces an allergen that wasn't previously present — can trigger a Class I recall (the most serious category, indicating a reasonable probability of serious health consequences).

The ingredient statement must list all ingredients in descending order of predominance by weight. This means the ingredient that weighs the most in your recipe comes first, and the ingredient that weighs the least comes last.

Use FDA common or usual names for ingredients. Declare Sugar not Sucrose. Declare Cream Cheese not Pasteurized Milk and Cream, Cheese Culture, Salt, Carob Bean Gum — unless you are declaring the sub-ingredients of a multi-component ingredient.

Water must be declared as an ingredient when it is added to the product and remains in the finished product. Water that evaporates during cooking (like water added to bread dough) is generally not declared because it is not present in the final product at a significant level.

The ingredient statement interacts with your allergen declaration. If you use the parenthetical allergen approach, allergen sources must appear within the ingredient list — Enriched Flour (Wheat Flour...). Get the ingredient list wrong and your allergen declaration may also be wrong.