Small Packaging: Are You Exempt from Including Nutrition Facts on Your Food Label?

When it comes to food labeling, the FDA has specific requirements to ensure that consumers have access to important nutritional information. However, not all food products are required to include a Nutrition Facts panel, especially when it comes to products packaged in very small containers. If your food product is packaged in a small package with limited space, you may qualify for an exemption. Here’s what you need to know.

Understanding the Small Package Exemption

The FDA recognizes that certain food products are packaged in containers so small that including a full Nutrition Facts panel may not be feasible. To address this, the FDA allows exemptions for food products packaged in very small packages, specifically those where the total surface area available for labeling is less than 12 square inches.

For these small packages, the exemption means that you are not required to include the full Nutrition Facts panel on your food label. However, there are still some important considerations to keep in mind:

1. Voluntary Disclosure: Even if your product qualifies for this exemption, you can still choose to include a Nutrition Facts panel. This can be beneficial for transparency and consumer trust, especially if your food product has strong nutritional qualities.

2. Alternative Labeling: If space permits, you may opt to include a simplified version of the Nutrition Facts or direct consumers to a website or other resource where they can access the full nutritional information, like with a QR code for example.

3. Other Mandatory Information: Although you may be exempt from including the full Nutrition Facts, other required information must still appear on the label, such as the statement of identity, net quantity, ingredient list, and allergen declarations.

Do You Qualify for the Small Package Exemption?

To determine whether your food product qualifies for this exemption, it’s important to measure the total surface area available for labeling. This includes all the space on the package that could reasonably be used for labeling, excluding the flaps and other non-labeling areas. If this total surface area is less than 12 square inches, you may be eligible for the exemption.

However, keep in mind that this exemption is specific to the small size of the package, and the FDA may still require nutrition information to be provided through other means, such as via a website or upon consumer request.

Why Consider Including Nutrition Facts Anyway?

Even if your product is exempt from the Nutrition Facts requirement, providing this information can still be valuable for your brand. Consumers are increasingly health-conscious and often seek out products with clear and transparent labeling. Including Nutrition Facts, even on small packages, can enhance consumer trust and differentiate your product in the market.

Need Help with Your Food Label?

Navigating FDA regulations can be complex, especially when dealing with exemptions like those for small packages. If you’re unsure about whether your food product qualifies for this exemption or need assistance with creating a compliant food label, we can help. Visit our Nutrition Analysis Services page or contact us to learn more about how we can support your business in developing accurate and effective food labels that meet regulatory requirements.