FDA Nutrition Facts
6 checksServing size must use household measures (cup, tbsp, tsp, oz) followed by metric equivalent in parentheses. Font must be equal or larger than the amount in cups — not smaller. Numeric amount must fall within realistic ranges for the product type.
Calories must be declared in a type size at least 60% larger than the serving size font. Total calories per serving must be bold or highlighted to stand out from other nutrient rows.
The % Daily Value (%DV) for each nutrient must be correctly calculated using FDA reference values. Common errors: saturated fat DV = 20g, dietary fiber DV = 25g, sodium DV = 2300mg, potassium DV = 4700mg. Values must round to the nearest 1% for amounts ≥1% DV and to the nearest 2% for amounts <1% DV.
Containers with ≥2 servings must display a dual-column nutrition facts table: "Per serving" and "Per package" columns, unless the serving size is the entire container (single-serving declarable). Missing dual-column on multi-serving products is a critical FDA violation.
Post-2020 FDA rule requires mandatory declaration of vitamin D and potassium in the nutrition facts panel. Calcium and iron remain mandatory. If vitamin D or potassium is absent from the label entirely, it must be included even if the amount is 0 mcg / 0 mg.
Calories value must not be preceded by qualifying language like "only" or "just" which could understate the caloric content. The calorie amount must be the most prominent number in the serving size row.
FDA Allergens
4 checksAll 9 major food allergens must be identified by their common name: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, sesame (added January 2023). Allergen must appear in the ingredient list AND in a "Contains:" statement. Missing any of the 9 is a critical FDA violation.
"Contains:" statement must immediately follow or be adjacent to the ingredients list. Must list allergens by their common names (not scientific names), separated by commas, in the exact order they appear in the ingredient list. Statement must not be hidden, truncated, or in smaller font than the ingredients.
"May contain" statements for allergen cross-contact must appear after the "Contains:" statement. "Made in a facility that processes X" advisory statements must not be the primary allergen declaration — they do not satisfy FDA allergen labeling requirements. Advisory statements alone do not protect against allergen liability.
"Fish" allergen requires declaration of the specific species if used (e.g., "cod", "salmon", "anchovy"). "Crustacean shellfish" requires the specific species (e.g., "crab", "lobster", "shrimp"). Generic "fish" or "shellfish" without species is acceptable but species-specific declarations improve compliance documentation.
FDA/USDA Labeling
3 checksNet quantity of contents must be stated in both US customary units (oz, lb) and metric (g, kg) on the same label. For FDA-regulated products the metric statement may follow the US statement in parentheses. USDA has separate net weight requirements for meat and poultry.
Country of origin (COO) or place of last substantial transformation must appear on the label for all food products. Required wording: "Product of USA", "Made in USA", "Packed in USA", or similar. Misleading COO claims can trigger both FDA and FTC enforcement.
The label must include the name and address (city, state, zip code) of the manufacturer, distributor, or packer. "For more information contact:" lines are acceptable but must include a full address. P.O. Box alone is insufficient.
Organic & Claims
3 checksThe USDA Organic seal may only be used by certified organic operations. Using the seal without valid organic certification violates federal law. The ingredient list must also reflect organic sourcing when the seal is present.
"Natural", "All Natural", "100% Natural" claims must not contain artificial or synthetic ingredients. "Natural" does NOT mean organic (no synthetic pesticides/fertilizers) and does NOT mean "no additives." Products making natural claims must not have artificial flavors, colors, or synthetic processing aids.
"0g Trans Fat", "Trans Fat Free", or similar claims may only be used when the product contains less than 0.5g of trans fat per serving. If the label claims 0g trans fat but the actual amount is ≥0.5g, the claim is illegal regardless of rounding rules.
FTC
2 checks"Made in USA" or "USA made" unqualified claims require that the product be "all or virtually all" made in the US. Marketers must maintain substantiation for such claims. "Assembled in USA" or "Designed in USA" from foreign components does NOT qualify as "Made in USA."
Environmental marketing claims must be qualified and substantiated. "Eco-friendly" without specifics is too vague and potentially deceptive. "Biodegradable" claims require proof of complete decomposition under typical disposal conditions. "Recyclable" claims require qualification if only part of the package is recyclable.
Barcode
3 checksUPC-A barcodes must be 12 digits; EAN-13 must be 13 digits. The final digit is a calculated check digit — if it does not match the calculated value, the barcode will not scan correctly. All leading zeros must be preserved; truncation at the barcode text field is a common error.
The barcode prefix (first 7-10 digits for a GTIN) must not start with 0 for EAN-13, and must use valid GS1 assigned prefixes. If the first digits match known invalid prefixes or reserved ranges (e.g., 000-009), the barcode is malformed. The company prefix must be registered with GS1.
Barcodes require a minimum clear zone (quiet zone) of 10x the narrow bar width on both left and right sides. If the label design crops or positions the barcode too close to text, graphics, or the label edge, the scanner may fail to decode it in retail or warehouse environments.