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  3. Food & Beverage Labeling 101: What Your Label Must Include Before Your First Production Run
GuideFor Buyers

Food & Beverage Labeling 101: What Your Label Must Include Before Your First Production Run

By USA Factory NetworkSeptember 24, 2026

A practical checklist of FDA label requirements for food and beverage brands, plus what your co-packer needs from you before labels and film go to print.

Food & Beverage Labeling 101: What Your Label Must Include Before Your First Production Run

Your formula is final, your co-packer has you on the schedule, and then someone notices the allergen statement is wrong. Now 20,000 printed labels are useless. Label mistakes are among the most common and costly reasons first production runs slip. And unlike a recipe tweak, a label error can't be fixed on the line.

This guide covers what U.S. food and beverage labels must include, how Nutrition Facts panels are built, and what to hand off to your co-packer before anything goes to print.

The two panels that matter

FDA rules split a package into two regulated areas.

Principal display panel (the front)

  • Statement of identity: the common name of the product ("Sparkling Water," "Granola Bar"). A fanciful name alone isn't enough.

  • Net quantity of contents: in both U.S. customary and metric units (e.g., "NET WT 12 OZ (340 g)"), placed in the bottom 30% of the panel.

Information panel (usually right of the front panel)

  • Nutrition Facts panel

  • Ingredient list: in descending order of weight, using common or usual names. Sub-ingredients go in parentheses.

  • Allergen declaration: the 9 major allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. Declare them in the ingredient list or in a "Contains:" statement.

  • Name and place of business: of the manufacturer, packer or distributor. Most co-packed brands use "Manufactured for" or "Distributed by" plus their company name, city, state and ZIP.

Building your Nutrition Facts panel

You have two options:

  1. Lab analysis: send finished product from a pilot batch to a food testing lab. It costs more but is the most accurate, and it's recommended for products with cooking loss, fermentation or moisture change.

  2. Database software: nutrition calculated from your recipe and ingredient specs. It's faster and cheaper but only as good as your inputs.

Either way, you're responsible for accuracy. FDA compliance testing allows some tolerance, but calories, sugars, total fat and sodium generally can't run more than 20% above the declared value. Run your numbers on the production formula, not the kitchen version.

Watch for added sugars, serving sizes (set by FDA's Reference Amounts Customarily Consumed, not your preference) and dual-column labeling for packages that could reasonably be eaten in one or two sittings.

Small business exemption: some very small companies can skip the Nutrition Facts panel, but it's lost the moment you make a nutrient or health claim. Most retailers expect a panel anyway.

Claims: where brands get into trouble

"Keto," "high protein," "natural," "gluten-free," "non-GMO" and "healthy" either have specific definitions or draw regulatory and legal scrutiny.

  • Nutrient content claims ("low sodium," "good source of fiber") must meet FDA thresholds.

  • Gluten-free means under 20 ppm gluten. Confirm your co-packer can support it with allergen controls and testing.

  • Certified claims (Organic, Non-GMO Project, Kosher) need the certification in place, often at the co-packer's facility too. Confirm this before you match.

  • "Made in USA" claims fall under FTC rules, and an unqualified claim means "all or virtually all" U.S.-made.

Special cases

  • Meat and poultry products: FSIS (USDA) regulates these, not FDA, and labels may need approval.

  • Alcoholic beverages: most need TTB label approval (COLA) before sale.

  • Dietary supplements: use a Supplement Facts panel and follow different rules.

  • Bioengineered foods: may require a USDA bioengineered disclosure.

What your co-packer needs from you

Your co-packer runs the product, but you own the label. Before your first run, have these ready:

  1. Final, approved artwork with the version number and date

  2. Product specification sheet that matches the label claims

  3. Allergen statement confirmed against the co-packer's allergen matrix and line schedule

  4. Lot code and date format (best-by vs. use-by), plus a clear print area on the packaging for it

  5. UPC barcode (licensed through GS1 US) placed where it will scan on the finished pack

  6. Packaging specs: dimensions, material, roll direction or label orientation for the co-packer's equipment

Pro tip: don't order a full print run before your pilot. Printed film and labels often have long lead times and high minimums. Use digital short-run printing for the pilot, then commit to volume once the formula and nutrition panel are locked.

Pre-print checklist

  • Statement of identity and net quantity on the front panel

  • Nutrition Facts built from the production formula

  • Ingredients in descending order by weight

  • All 9 major allergens reviewed and declared

  • Every claim backed by a definition, test or certificate

  • Business name and address included

  • Lot code area and UPC placement confirmed with co-packer

  • Artwork signed off by a regulatory reviewer

Next step

Need a co-packer that can support your certifications, allergen needs and packaging format? Get matched free →

This guide is for general information and isn't legal or regulatory advice. Have a qualified food regulatory consultant review your final label.

labelingfdanutrition factsallergenspackagingcomplianceco-packing