14.2 Labeling requirements and health claims

Mandatory Label Components

Food labels are one of the primary tools consumers have for evaluating what they're eating. In the U.S., the FDA regulates what must appear on packaged food labels, and understanding these requirements is a core part of food safety management. This section covers the required elements, the types of claims manufacturers can make, and special labeling programs like organic certification.

Nutrition Facts Label and Serving Size

The Nutrition Facts label is the standardized panel you see on nearly every packaged food product. It lists serving size, calories, macronutrients (fat, carbohydrates, protein), and key micronutrients (vitamins and minerals). Its purpose is to give consumers a consistent format for evaluating and comparing products.

Serving size is the foundation of everything else on the label. It reflects the amount of food typically consumed in one sitting (for example, 1 cup of cereal or 1 slice of bread). All the nutrient values listed on the panel correspond to that serving size, so if you eat two servings, you need to double every number. The FDA updated serving sizes in 2016 to better reflect how people actually eat, which is why some serving sizes are larger than they used to be.

Ingredient List and Allergen Declarations

The ingredient list displays every ingredient in the product, arranged in descending order by weight. The first ingredient listed is present in the greatest amount. This ordering matters: if sugar appears as the first or second ingredient, that tells you a lot about the product's composition.

Allergen declarations are required under the Food Allergen Labeling and Consumer Protection Act (FALCPA). Manufacturers must clearly identify the presence of the major food allergens:

• Milk
• Eggs
• Fish
• Crustacean shellfish
• Tree nuts
• Peanuts
• Wheat
• Soybeans
• Sesame (added in 2023 under the FASTER Act)

These can appear within the ingredient list itself (with the allergen named in parentheses) or in a separate "Contains" statement, such as "Contains: Wheat, Soy." For people with food allergies, this labeling can be life-saving.

Percent Daily Value (%DV)

The Percent Daily Value (%DV) tells you what percentage of the recommended daily intake of a nutrient one serving provides. It's based on a 2,000-calorie diet for healthy adults.

A quick rule of thumb for interpreting %DV:

• 5% DV or less = the food is low in that nutrient
• 20% DV or more = the food is high in that nutrient

This makes it easy to compare products side by side. If you're trying to limit sodium, for instance, you'd look for products with a low %DV for sodium. If you want more fiber, you'd look for a high %DV.

Claims on Labels

Not everything on a food label is required. Manufacturers can voluntarily add claims to highlight nutritional benefits, but these claims are regulated to prevent misleading consumers. There are three distinct types, and they differ in how much FDA oversight they receive.

Health Claims and Structure/Function Claims

Health claims describe a relationship between a food or food component and a reduced risk of a disease. These require FDA authorization and must be backed by significant scientific agreement.

Notice the careful, qualified language. The FDA requires that health claims not overstate the evidence.

Structure/function claims are different. They describe how a nutrient affects the normal structure or function of the body, but they do not claim to reduce disease risk. These do not require FDA pre-approval, though they must be truthful and not misleading. Products bearing structure/function claims must include the disclaimer: "This statement has not been evaluated by the FDA."

The distinction matters: "calcium builds strong bones" (structure/function) is very different from "calcium reduces the risk of osteoporosis" (health claim). The second requires FDA authorization; the first does not.

Nutrient Content Claims

Nutrient content claims use specific terms to characterize the level of a nutrient in a food. Each term has a precise FDA-defined threshold:

• "Free" — negligible amount (e.g., "fat-free" means less than 0.5g fat per serving)
• "Low" — a small amount (e.g., "low sodium" means 140mg or less per serving)
• "Reduced" — at least 25% less of a nutrient compared to the reference food
• "High" or "Excellent source" — 20% DV or more per serving (e.g., "high in fiber" means 5g or more per serving)
• "Good source" — 10–19% DV per serving

These terms aren't interchangeable, and manufacturers can't use them loosely. If a product says "low fat," it must meet the specific FDA criteria for that claim.

Special Labeling

Organic Labeling

Organic labeling is regulated by the USDA (not the FDA) and indicates that a product was produced following specific agricultural practices. These practices promote ecological balance and conserve biodiversity while prohibiting synthetic fertilizers, most synthetic pesticides, and genetically modified organisms (GMOs).

There are distinct tiers of organic labeling based on ingredient composition:

• "100% Organic" — every ingredient is certified organic; can display the USDA Organic seal
• "Organic" — at least 95% of ingredients are certified organic; can also display the USDA Organic seal
• "Made with Organic Ingredients" — at least 70% of ingredients are certified organic; cannot use the USDA seal but can list specific organic ingredients on the front panel

Products with less than 70% organic ingredients can only mention organic ingredients in the ingredient list, not on the front of the package. Understanding these tiers helps you evaluate what an "organic" label actually guarantees about the product you're buying.