Produce a Nutrition Facts panel that survives an FDA pull — the right serving size, the right rounding for each nutrient, and numbers you can defend.
Do these first
Real help from real food people
Chef Diego runs a real food plant. If this page didn't get you there, tell us — a person reads every message.
By the end of this lesson you can tell whether you even owe a Nutrition Facts panel, set your serving size the way the regulation makes you, round each nutrient to its own increment, and keep the source data that lets you stand behind every number. The trap that catches careful people here is subtle: a number that came straight off an accurate lab report can still your label if you round it wrong. This lesson works the panel in build order — do I owe one, what's the serving, what are the numbers, how do I round them — so you finish with a panel that holds up.
Most packaged foods carry a Nutrition Facts panel under 21 CFR 101.9, and the anatomy of a compliant label lesson already put it on the label as one of the five elements. But there are two real exemptions, and they're worth checking before you pay for a single lab test.
The first is for low-volume direct sellers. If you make direct sales to consumers — a farmers-market stand, your own shop — and your business does no more than $500,000 in total annual sales, or no more than $50,000 of that in food sales to consumers, you can skip the panel, as long as your label carries no nutrition claims at all (21 CFR 101.9(j)(1)).
The second is the small-business exemption, and it turns on headcount and volume, not dollars. For any 12-month period you qualify if, over the preceding 12 months, you employed fewer than an average of 100 full-time-equivalent employees and sold fewer than 100,000 units of that particular product in the United States. To use it you file a notice with FDA before the period begins. There's a smaller tier inside it: if you're not an importer, employ fewer than 10 full-time-equivalent employees, and sell fewer than 10,000 units of the product a year, you don't have to file the notice at all (21 CFR 101.9(j)(18)).
A single claim voids the exemption
Every one of these exemptions disappears the moment your label makes a nutrition claim. "Low sodium," "good source of fiber," even "0 g trans fat" on the front of the package is a nutrient-content claim — and making one pulls you straight back into needing a full, correct panel, plus the rules that govern the claim itself. Decide the claims question before you decide the panel question.
These numbers move you back in as you grow, so don't treat a one-time check as permanent. Confirm your own eligibility against 21 CFR 101.9(j) and FDA's Small Business Nutrition Labeling Exemption page (verified July 2026), and re-check it each year. One more scope note: this is the FDA panel for FDA-regulated packaged food. Meat, poultry, and processed egg products are nutrition-labeled under USDA/FSIS rules instead. If you owe a panel, the rest of this lesson is how to get it right.
The most common mistake is treating the serving size as a marketing lever — shrinking it so the calories and sugar look smaller. You can't. The serving size is set by regulation.
It comes from the (RACC) that FDA publishes for your food's category in 21 CFR 101.12. You take the reference amount for your category, convert it to a household measure a shopper understands (a cup, two tablespoons, three cookies), and that's your serving. Your opinion doesn't enter into it.
Two consequences trip up first-timers:
This matters because every value on the panel is per serving. Set the serving wrong and every number below it is wrong too, no matter how carefully you round.
Here's the part that misbrands technically-correct labels. Your lab report might say a serving has 8.2 grams of fat and 137 milligrams of sodium. Neither of those numbers goes on the panel as written. FDA sets a rounding increment for each nutrient, and printing the raw figure — or rounding it to the wrong increment — misbrands the label even though the underlying data was perfect.
is spelled out in 21 CFR 101.9(c). The increments that catch people most:
| Nutrient | Round to | Declared as 0 (or "less than") |
|---|---|---|
| Calories | nearest 5 up to and including 50, then nearest 10 | under 5 calories may be 0 |
| Total fat, saturated fat, trans fat | nearest 0.5 g below 5 g, then nearest 1 g | under 0.5 g is 0 |
| Cholesterol | nearest 5 mg | under 2 mg may be 0; 2–5 mg may say "less than 5 mg" |
| Sodium | nearest 5 mg from 5–140 mg, then nearest 10 mg | under 5 mg is 0 |
| Total carbohydrate, dietary fiber, sugars, protein | nearest 1 g | under 1 g may say "less than 1 g"; under 0.5 g is 0 |
Worked through: 52 calories rounds to 50, but 78 rounds to 80. That 8.2 grams of fat rounds to 8 grams; 3.3 grams rounds to 3.5; 0.4 grams is declared as 0. The 137 milligrams of sodium rounds to 135, while 143 milligrams rounds to 140. Each printed figure is the legally correct one — and each differs from the lab number you started with.
Declaring 0 is not the same as claiming 0
Rounding a tiny amount down to 0 on the panel is allowed. Putting "0 g" or "calorie-free" on the front of the package is a different act — that's a nutrient-content claim with its own definition to meet, and, as above, it can cost you an exemption. The panel value and the marketing claim follow separate rules; don't let a rounded-down 0 talk you into a front-of-pack claim.
Added sugars follow the gram rules, and you can skip declaring them only when a serving has less than 1 gram and you make no sweetener claims. The panel's four required vitamins and minerals — vitamin D, calcium, iron, and potassium — are declared as both an absolute amount and a percent Daily Value, and they carry their own rounding in the same section. When you're unsure of an increment, read it off 101.9(c) rather than assuming it matches the nutrient next to it.
You get your nutrient values one of two ways: send finished product to a lab, or calculate them from a nutrient database or nutrition-analysis software built on reference data like USDA's FoodData Central. Both are legitimate — FDA even recognizes an approved database, computed by its guidelines, as an alternative to laboratory analysis (21 CFR 101.9(g)(8)). Calculation is cheaper and faster; lab analysis is more defensible for a complex or highly processed product. Pick per product, not by habit.
Whichever you choose, the number has to survive a test you don't control. FDA checks a panel by analyzing a — 12 subsamples from a lot, run by standard methods (21 CFR 101.9(g)). The tolerances run in two directions:
So the real deliverable isn't the panel — it's the file behind it. Keep the recipe, the database calculation or the lab report, and your serving-size math together, dated. That file is what turns "the label says 8 grams" into a number you can defend when someone asks how you got it.
Work the panel in order: confirm whether you owe one, set the serving size from the reference amount, get your numbers, round each nutrient to its own increment, and file the source data behind it. Do those five and the panel is both correct and defensible.
Keep one habit for good — these rules and the reference amounts change, so check 21 CFR 101.9 live before you finalize a panel rather than copying one off a competitor's box. With the numbers right, the next thing the label has to get exactly right is the allergen declaration — the nine major allergens, sesame now among them — which is the next lesson in this course. And any marketing claim you're tempted to add, the kind that can void the exemption you just checked, is its own set of rules, covered in the claims lesson that follows.
Do this in your operation