Guidelines for Dietary Labeling on Food Products

From humble beginnings as a basic list of ingredients, “dietary labels” on food and beverage products have evolved into a wide range of information panels, encompassing nutritional content and allergens in the recipe. Together, these labels form a comprehensive guide for consumers to assess the value and safety of the food and beverage products they’re buying. 

Dietary labels are stringently regulated by bodies like the FDA to ensure they properly inform consumers. Following mandated guidelines for dietary labeling is key to protecting public health, as well as ensuring legal compliance — so it’s critical to understand requirements and avoid common labeling challenges and mistakes. 

What’s Required for Dietary Labels 

Dietary labels are best understood as a category of food labels required on packaging, specifically: 

1. The nutrition facts panel
2. Ingredients label
3. Allergen label

Each label has a specific set of content requirements and rules to follow in order for packaging to meet compliance standards. Here’s what you need to know about each: 

1. The Nutrition Facts Panel 

The nutritional facts panel is a detailed listing on food packaging that provides information about the nutritional content of the product, helping consumers make informed dietary choices. It must contain: 

• Servings per container 
• Serving size  
• Household measure / common household unit   
• Total calories 
• Total fat 
• Saturated fat 
• Trans fat 
• Cholesterol 
• Sodium 
• Total carbohydrate 
• Dietary fiber 
• Total sugars 
• Added sugars 
• Protein 
• Mandatory vitamins and minerals of vitamin D, calcium, iron, and potassium 
• Other nutrients permitted in the nutrition panel can be voluntarily included but are mandatory if they are the subject of a claim.

In 2016, a number of new labeling requirements went into effect requiring larger, easier to read text, and more informative serving sizes, which occasionally still create compliance challenges for food and beverage manufacturers. It’s important to note that having even one number off in the nutrition panel can put the labeling out of compliance.

2. Ingredient Statements 

The ingredient statement on food packaging provides a list of all ingredients used in the product, arranged in descending order by weight. This helps consumers understand what goes into the food they are consuming, especially for those with dietary restrictions or preferences. 

The FDA mandates use of a font size no smaller than 1/16th inch based on the lowercase “o” or, if using all uppercase letters, based on the uppercase letter height. The statement is most often placed on an information panel in conjunction with the nutrition and responsible company information. Ingredients must be labeled using their prescribed names as per regulations or, if none exists, their common or usual names to ensure clarity and transparency for consumers.

3. Allergen Declaration 

The Food Allergen Labeling and Consumer Protection Act of 2004 (FALCPA) mandates that product packaging clearly declare the presence of any major food allergens. As of current writing, the major food allergens in the U.S. are: 

• Milk 
• Eggs 
• Fish 
• Crustacean shellfish 
• Tree nuts 
• Wheat 
• Peanuts 
• Soybeans 
• Sesame 

Complete and clear allergen declaration is critical for manufacturers to meet compliance standards, inform consumers, and avoid recalls. That includes identifying and labeling required allergens even when ingredient names aren’t obvious. For example, “Sodium Caseinate” is derived from milk but doesn’t have the word “milk” in its name; regardless, it’s mandated that manufacturers list milk as an allergen on the packaging of products with this ingredient. 

Allergen declarations may appear on the label either:

• In parentheses following the name of the ingredient, such as “flour (wheat),” “lecithin (soy),” and “whey (milk)” 

— or —  

• Immediately after or next to the list of ingredients in a “contains” statement, such as “Contains wheat.” 

Examples of Special Food Labeling Rules 

Dietary labeling requirements have evolved dramatically in recent years as the FDA better aligns packaging with consumer needs. Some of the biggest recent changes include: 

New “Healthy” Labeling Requirements 

In 2022, the FDA proposed updating the definition of the voluntary "healthy" nutrient content claim for food labeling to ensure nutrient-dense foods from recommended food groups actually qualify for the "healthy" claim while setting specific limits for added sugars, saturated fat, and sodium based on Daily Value percentages. 

The new proposed definition has been one of the first times the agency has focused on food groups for the basis of the claim rather than just nutrient content. The goal is for this to limit random fortification by food manufacturers just to meet the nutrient requirements of a claim, ensuring “healthy” labeled foods actually contain a certain amount of food groups like grains, fruit, or vegetables. 

Plant-Based Milk Alternatives (PBMA) 

An FDA draft guidance issued in February 2023 recommends that plant-based milk alternatives (such as soy, almond, oat, and other dairy-free “milks”) include a voluntary nutrient statement that compares them to traditional dairy milk based on USDA criteria. The goal is to improve transparency about the actual nutritional values and health benefits of non-dairy milks as they become increasingly popular among consumers. 

Ensure You Meet Nutrition Labeling Requirements With AIB International 

Navigating the complex landscape of dietary labeling regulations and consumer demands for transparency often requires the kind of guidance that only expert third-party consultants can provide. For over a century, AIB International has offered invaluable insight, resources, and education to help food and beverage companies meet compliance requirements and stay ahead of the ever-evolving dietary labeling landscape. 

Ensuring food labeling compliance begins with properly training staff to follow the rigorous standards set by the FDA. Learn more about getting your team up to speed in our FDA Food Labeling Online course or our virtual Labeling of FDA Food Products course (which features a live trainer).