Food labels – Nutrition Facts for the USA – what you need to know

Labelling food products for sale in the USA requires some information that MUST be included, but which are not required in the UK/EU.

 

NutriCalc Premium will generate a compliant label image for a Nutrition Facts label for food products that include:

• a serving size description e.g. ‘3 cookies’
• the serving size weight
• the number of servings per container
• the number of calories per serving
• values for the following nutrients together with the % of the Daily Value supplied by the serving (apart from three exceptions as stated):

    • Total Fat
    • Saturated Fat
    • Trans Fat (no daily value)
    • Cholesterol
    • Sodium
    • Total Carbohydrate
    • Dietary fiber
    • Total Sugars (no daily value)
    • Added Sugars
    • Protein (no daily value)
    • Vitamin D
    • Calcium
    • Iron
    • Potassium

Values are expressed in grams, except for vitamin D (micrograms) and cholesterol, sodium, calcium, iron and potassium (milligrams).

There are rules for rounding nutrition values and the % daily values, which may be different for each nutrient type, for example:

for calcium, values of:

• less than 5mg: express as 0
• 5-140mg: nearest 5mg
• over 140mg: nearest 10mg

and % daily values of

• up to 10%: nearest 2%
• over 10% and up to 50%: nearest 5%
• over 50%: nearest 10%

The calculation for total carbohydrate includes the dietary fibre, stated as ‘dietary fiber’, which should be considered when handling data for ingredients and products which have been calculated elsewhere and only the available carbohydrate value is available.

Energy (calories) is obtained from the formula 9 x fat + 4 x protein + 4 x total carbohydrate (plus 7 x alcohol if present). There is therefore no separate factor for fibre.

‘Added sugars’ includes any sugars that are not naturally-occurring such as in Glucose syrup, as well as any naturally-occurring sugars added solely to sweeten the product, such as in honey.

The Nutrition Facts label must also have a footnote about the Daily Values, stating ‘The % Daily Value (DV) tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice’.

There are also strict requirements regarding which nutrients should be highlighted and the layout and size of the separator bars.

As is the case with UK/EU labelling, the portion size must be realistic and not misleading in any way.

Nutrition values may be obtained from calculation or from laboratory analysis.
For full information:

American Food and Drug legislation is given in CFR – Code of Federal Regulations Title 21.

Food labelling is laid down in part 101: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?CFRPart=101

and nutrition labelling is in subpart 101.9: https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/CFRSearch.cfm?fr=101.9

Also please be aware that, when exporting to the USA:

• you will also need to ensure that you have registered with the FDA if you manufacture, process, pack, or store, food, beverages, or dietary supplements for consumption in the United States either by humans or animals.

• a barcoded confirmation number issued by the FDA must accompany all shipments.

• companies located outside the United States must designate an agent for FDA communications as all products sold in the USA must include the name and address of someone in the USA

• the names of foods in the USA may differ from the EU e.g. ‘chips’ and ‘crisps’

• there are around 300 standardised products in the USA the standards of which are probably NOT the same as those in the UK & EU. And your product may not be permitted entry if it does not comply

David F Bartley PhD

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