Crash Course: Breaking Down FDA Labeling Requirements for Grocery Brands

Consumer food spending is at its highest level in more than four decades. According to the U.S. Department of Agriculture (USDA), U.S. consumers spent 11.3% of their disposable personal income on food in 2022 — and prices are only rising. As a result, buyers are becoming more particular about what they purchase and comparing products. 

Labels play a major role in this process. From nutrition data to ingredient lists and allergen information, consumers depend on labels to keep them informed.

To ensure brands are honest and transparent about what’s in their products and what this data means for consumer health, the U.S. Food and Drug Administration (FDA) has created labeling requirements that all food brands must follow.

This creates a dual challenge for brands. First, they must ensure labels meet current guidelines and convey the required information. And second, they must be prepared to adjust label processes as FDA regulations evolve.

Frustrated with food fact fluctuations? Here’s a crash course in FDA labeling requirements.

What Are the Primary FDA Labeling Requirements?

There are several FDA labeling requirements for food labeling. These include the Nutrition Labeling and Education Act (NLEA) of 1990, the Food Allergen Labeling and Consumer Protection Act (FALCPA) of 2004, and the Food Safety Modernization Act (FSMA) of 2011. Here’s a look at each in more detail.

Nutrition Labeling and Education Act (NLEA) 

The Nutrition Labeling and Education Act (NLEA) was enacted in 1990. This act specifies the type of information that labels must display and the way this information must be displayed. For example, under the NLEA, brands may state on labels that their product is “sugar-free” if the product contains less than 0.5g of sugar per reference amount for labeled serving sizes.

Brands can also state that foods have “reduced” or “less” sugar if they contain at least 25% less sugar per reference amount than an appropriate reference food. Brands can’t use this type of claim on dietary supplements of vitamins and minerals.

Food Allergen Labeling and Consumer Protection Act (FALCPA)

Passed in 2004, the Food Allergen Labeling and Consumer Protection Act (FALCPA) protects consumers by requiring brands to list potential allergens on their packaging. Not only are these allergens potentially deadly, but research found that 25% of foods tested failed to list allergens such as eggs or peanut butter on their ingredient lists. 

To combat this issue and lower the risk of allergic reactions, the FDA requires ingredients in food to be listed by their common name. If this common name does not clearly indicate the presence of an allergen, brands must have the allergen connected with the food source.

Food Safety Modernization Act (FSMA) 

The Food Safety  Modernization Act (FSMA) of 2011 focuses on improving food manufacturing and shipping processes to increase public safety. For example, the act includes provisions for the registration of food facilities, the standardization of safety procedures, and the sanitary transportation of food. 

The FMSA also requires that companies include packaging labels that state the name and location of where the food was manufactured or processed.

What Specific Information Is Required on Food Labels?

There are three primary categories of information required on food labels:

Nutrition Facts

The Nutrition Facts label includes product information such as serving sizes, the total number of calories per serving, and the amount (in both grams and percent of daily value) of specific components within a food item. In 2021, nutrition labeling requirements were updated to reflect FDA research on consumer behavior.

Nutrition Facts labels have six essential sections:

1. Servings per container and serving size. The FDA recently updated serving sizes to reflect what consumers actually eat and drink. For example, the serving size for ice cream has increased from ½ a cup to ⅔ of a cup.
   
2. Total calories per serving. Brands are now required to make the “Calories” font both larger and bolder to make it easier for consumers to find. 
3. Fats, cholesterol, sodium, total carbohydrates, and protein by grams per serving and percent daily value (except for proteins, which can be listed as grams only).
4. Added sugars, which include sugars added during the food processing or include sugars from syrups, honey, or fruit and vegetable juice.
   
5. Nutrients including vitamin D, calcium, iron, and potassium, are listed as milligrams or micrograms per serving along with percent daily value.
6. Footnote stating that the percent daily value specifies how much a nutrient in a serving contributes to a 2,000-calorie per-day diet. 

Ingredient Lists

According to the FDA, products must also list the ingredients they contain. Ingredients should be listed in descending order of prominence by weight, which means the ingredient with the highest weight is listed first, and the ingredient that weighs the least is listed last. 

Ingredient lists must appear on the same label panel that contains the name and address of the manufacturer or distributor. Ingredients should be listed using their common names — “sugar” instead of “glucose” or “fructose” — and water is considered an ingredient.

Allergen Declarations

Labels must contain information about major allergens, per FDA guidelines. Brands have two choices for listing allergens. 

First is listing allergens in parentheses immediately after the ingredient, such as “whey (milk).” Brands may also choose to list all allergens after the ingredients using a “contains” statement, such as “Contains wheat, soy, and peanuts.”

What Purpose Do FDA Labeling Requirements Serve?

The primary purpose of labeling requirements is consistency. By compelling brands to use standardized label formats and information types, products can be easily compared across common categories, such as the amount of sugar, fat, or salt they contain.

Without these requirements in place, manufacturers and retailers could choose to under- or over-report ingredient quantities, making it impossible for consumers to shop confidently.

This confidence forms the second purpose of standardized labeling. As noted by recent research from Purdue University, more than 70% of consumers trust or completely trust ingredient lists, and 65% trust nutritional information.

However, less than half of consumers are confident that brands are telling the truth regarding claims about the health benefits of the “naturalness” of food. Evolving FDA regulations are designed to bolster consumer trust by providing a shared roadmap for label data.

The final piece of labeling is transparency. By requiring grocery brands to provide data about where ingredients originate, how they were handled, and how the final product was created, both consumers and the FDA benefit from food transparency.

For buyers, this translates to improved confidence in buying decisions, since they know where ingredients originated, where they were processed, and how they were handled. For the FDA, transparency makes it easier to pinpoint problems in supply or manufacturing chains and take targeted action. 

There’s still work to be done, however. 

For example, while food packaging is required to display expiry dates, there’s no standardization of the method used to calculate these dates. This means that similar brands could sell similar products with similar ingredients but list wildly different expiry dates.

Ongoing FDA work will hopefully take steps to ensure expiry dates are calculated using specific, shared criteria. 

What Steps Can Brands Take To Streamline Label Compliance?

To streamline FDA labeling requirements for food, grocery brands are best served by software solutions capable of both supporting current requirements and adapting to new expectations.

This means prioritizing features like content validation, label analysis, and standards comparison.

Content Validation

The changing nature of FDA label requirements means that brands can’t rely on previous label versions matching current expectations. As a result, it’s critical to leverage tools that combine artificial intelligence (AI) and human content validation to ensure that label information is accurate, up-to-date, and compliant.

Label Analysis

Next-generation grocery software includes features such as nutrition label visualization, which allows brands to see what labels will look like and ensure all FDA-required data is present and formatted correctly. 

Standards Comparison

It’s also worth investing in solutions that leverage industry-wide experience in the form of grocery category guides. These guides help ensure that product content meets the latest industry, retailer, and regulatory standards. 

Poor labeling processes can put brands at regulatory risk. Agile, scalable grocery software can help companies stay current, compliant, and confident in label data.