Confectionery Labels: FDA Labeling Guidelines Made Simple
Your labels aren’t only aesthetic branding pieces that should make you look good—first and foremost they are “information sheets”. The efficient label needs to provide your customers with relevant and accurate information so that they are sure your product does answer their needs (and why you’re better than competition).
Especially with food, the critical consumer needs everything to be clear before buying your sweet offerings. Your custom labels should instruct them how to enjoy your products to the fullest, and this includes info about list ingredients (percentages, allergens if any, substitutes, etc.), safe handling and storage (so they can eat it in the form and freshness level that it was meant to be enjoyed in), and other brand benefits to make your case when comparing your offerings with another product.
Your goal in printing your custom confectionery labels is to provide your customers and prospective customers with something well-presented that will validate food facts and give them peace of mind.
Yes, pretty labels will get you noticed—but correct and accurate labels are what set well-built businesses apart from the impulsive, any-way-the-wind-blows rookie. We’ve seen it with our clients. Correctly-assembled labels gets (and gets to keep) more customers.
If you’ve tried to reference the FDA Food Labeling Guide, you’ll know that all these “labelling requirements” and regulations jargon can get extremely confusing real fast. However, following the guide is key in making sure your custom confectionery labels make the cut, especially with discerning prospective customers. What to do?
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Keep in mind though that there are still exceptions and variations to the guidelines for specific product categories. When in doubt, check the full FDA Food Labeling Guide for complete details. You can simply annex the information based on what section it is that you need to clarify. Still saves you tons of time.
Let’s begin with defining the labels that you’ll be printing. These are called “Label Panels” and are the lifeblood of your products, especially if you don’t have a comprehensive website just yet.
Your confectionery custom labels must have at least two distinct areas, and these are the Principal Display Panel or Primary Display Panel (PDP) and the Information Panel (IP). Both will of course correspond with label “artwork”, the term we use for files that go to print. The PDP and IP can be separate, front and back labels, or one large wraparound label, depending on what you feel will suit your container/packaging style.
Primary Display Panel (PDP)
A.K.A. your front panel, or the main label that is meant to catch the attention of your customer
This is the first thing customers see if you’re selling these in retail. These would be the labels (or part of a large wraparound label if you aren’t printing two parts) that will be front-oriented to be displayed on store shelves.
WHAT TO INCLUDE HERE:
What your product is (formally known as the Statement of Identity [link to section below]) and how much of the product is in the packaging (your Net Quantity Statement[link to section below]).
Information Panel (IP)
A.K.A. the supplemental panel, which holds supporting information or elaboration on ingredients, people, and processes
For the IP, you’d want to place that to the right, left, rear, top, or bottom of the PDP, but primarily this would be on the immediate right. Place it elsewhere (left, rear, top, or bottom) if your packaging style makes it hard to place the IP on the right of your PDP. It’s important that you EXCLUDE any graphics or unnecessary art elements here. We want to be as clear and straightforward as we can with the presentation of information.
FOUR THINGS TO INCLUDE HERE:
1) Name + address of manufacturer (who created the product), the packer (who placed the product in its packaging), or distributor (who moves the product into stores or local shops where customers can purchase the product)
If you’re the manufacturer and you are listed in the current directory or phone book, you can simply put city or town, state, ZIP (or mailing code if you’re outside the USA). If you aren’t listed, it’s required that you include your street address. However, if your assembly line also includes an outsourced packer and distributor, make sure to include their relation to your product (“manufactured for”, or “packed by”, or “distributed by”).
2) Chances are, your confections are comprised of two or more ingredients—this is the requirement to include an ingredient list.
Ingredients need to be listed from greatest to least by weight and must be found on the same panel as your product’s name and your firm’s address. This can be placed before or after the nutrition facts, depending on your preferred layout.
If your main ingredients are composed of sub-ingredients (your homemade cake syrup, for example) you can make this more cohesive by listing the main ingredient first and then listing what you used to make this main ingredient, enclosed in parentheses. It would look like this: CAKE SYRUP (CORN SYRUP, WATER, COCOA, SUGAR, VANILLA)
Alternatively you can just list down all your sub-ingredients as main ingredients. Again, remember to list everything from greatest to least by weight. In this case, remove “CAKE SYRUP” and simply list down everything that you used to create your sweet sensations.
3) Nutrition Facts need to be specified and placed together with the ingredients list + name and address on either PDP or IP.
If you’ve got a ton of text on your IP, Nutrition Facts will go on the immediate right panel, or on any highly visible panel on your packaging. More on how to design and present info on the Nutrition Facts section below.
4) Are you using ingredients in your product formula that are classified as allergens? Check out the eight major allergens below.
– Fish (should be specific)
– Crustacean shellfish (should be specific)
– Tree nuts (should be specific)
If so, you need to add allergen labelling, and this text must be as large as the ingredients text. For naming on your confectionery labels, there are two ways to do this.
–> You can list the major food allergen followed by the name of its food source in parentheses: “whey (milk)”.
–> You can also start with the word “Contains” followed by the food source immediately after the ingredients: “Contains: milk.” If more than one, list all the allergens after each other: “Contains: eggs, peanuts, and soybeans.”
Advisory allergen labelling isn’t required, but you can certainly add this as long as it doesn’t interfere with the other required info: “May contain eggs, peanuts, and soybeans.” or “Processed in a facility that also processes eggs, peanuts, and soybeans.”
If your confectionery products contains alcohol in excess of 1⁄2 of 1 percent by weight, that fact must be stated on your label. If you’re selling directly to consumers as in trade fairs and events and have unpackaged or unlabelled products that are ready-to-eat, you should have a written notice at your stall or shop to let your customers know of this. The FDA states that confectionery products must not contain any alcohol in excess of 5 percent by weight.
Make sure that all relevant info on your label is easy to read. Legible fonts will be more consumer-friendly. Chances are, if your labels are hard to read and some information are concealed because of this, they won’t be buying your product. Good copy and branding should be supported by readable text styles and sizes. A good benchmark would be to make sure your smallest text is at least 1/16 inch in height. If you’re selling outside of the USA, accurately-translated text in the native language/s of where you are elsewhere selling is and investment you shouldn’t cut corners on.
Your custom labels must be printed on materials that do not contaminate your product. Our label stocks, soy-based inks, and acrylic adhesives are safe for food use—but it is best if your custom confectionery labels don’t touch your product, to make sure everything is kept sanitary and there are no outside contaminants.
Now that we’ve settled everything that needs to go on your PDP and IP, let’s move on to where and how this should all be placed on your custom confectionery labels.
DEFINE THE PLACEMENT OF YOUR LABELS
When looking at labelling areas on your packaging, exclude flaps, closures, shoulders, and necks—these are areas where text can get cut off. You can certainly include the bottom of a box (e.g., pre packed cookies box). Take note that the area is determined by the total area available for labelling on the container, and not simply the size of the label applied on it. There are specific exceptions, and they’re listed as follows:
1) If you’ve got enough room, you can place all the required Information Panel (IP) content on your Primary Display Panel (PDP).
2) You can split the IP content into two Information Panels if you can’t make it fit into just one panel. If you’re doing this, make sure that the information in each section is kept together and not split up among the two panels.
3) If you’re really tight on space and have LESS THAN 12 in² (77.42cm²) for your labelling area, you can just put a phone number or address and point the customer to these contact details for nutrition information. It’s the same rule for containers that are unusually-shaped and because of this don’t have a sufficient labelling area.
TYPE (TEXT) FORMATTING RULES FOR INFORMATION PANEL (IP) CONTENT
1) Regardless of your chosen font, your text must be at least 1/16 inch (1.6mm) tall. This is based on the lowercase letter o (or uppercase O if using all uppercase letters).
2) Keep it proportionate. The height of letters can’t be more than 3 times their width.
3) All required information should be easy to read. High contrast (such as black text on white background) is key.
4) Working with a brand identity that focuses on (foreign) culture? When using a foreign language anywhere on your packaging, check that all required information is in both English as well as the foreign language that is applicable.
5) You can pull of your aesthetic concept, but it shouldn’t be too far of from what your product is. Your label artwork shouldn’t be misleading (false advertising, in a sense) and shouldn’t take away from the visibility of the required information.
*NOTE: The Nutrition Facts Panel has its own guidelines below.
A.K.A. “Statement of Identity” which can be either the “common name” or a “fanciful name” of your sweet creations
When printing custom labels, this is obviously the first thing that you would have already been set on, even before your brand name. This is the name of what you are selling; and if you’re using a fanciful name (“Dark Decadence”, which is a type of cookie, for example) make sure this is accompanied by a descriptive phrase at least 1⁄2 the type size of the product name so that your customers can identify right away what the product is.
When selling a flavored product, let them know that it isn’t a naturally-occuring flavor. For example, say “blueberry flavored chocolate”. And, more importantly, if your flavoring isn’t derived from a natural source, then your custom label should say so. In this case, “ artificially flavoured blueberry chocolate”.
If applicable, your food name should also describe the form to correctly identify what you are offering. Examples would be “sweet tarts with sliced apples” or “sweet tarts with pureed apples”.
A.K.A. you, and everybody else who made the production, packaging, and distribution of your confectionery product possible
We tackled this a bit in the Information Panel (IP) section above. To iterate, this ID on your confectionery label is part of your production and supply chain. This can simply include your kitchen, a company that packages your products, or mainlines that are authorised to sell your perishable products.
On your custom label, add the firm (manufacturer, packer, distributor) to help customers identify the responsible party/parties. This not only gives your customer confidence that they are purchasing a product from a legitimate source, it also is required by law if any food spoilage or complaints arise.
Unless you are the actual manufacturer, other companies that will help you produce and sell your product should be included and must have a qualifying phrase that lets the customer know what their relation is with your brand. For example, “manufactured by Connie’s Kitchen” or “baked especially fresh everyday by Peters and Co.” would have “exclusively distributed by Wholefoods Organic Market” if you aren’t selling anywhere else.
Any firm that you are using, even if they are a small business or an organisation, should also have its city, state, and zip code declared on your confectionery labels. If the firm is not listed in the current telephone guide for that city, it’s best that the street address is also listed.
A.K.A. how much your product weighs, minus the container or wrapper of course!
How much sweets can you eat? The net quantity is the declaration of the specific amount of product, stated in both US (inches/pounds/fluid ounces) and metric (grams/liters) units, and can come in many forms:
– Net weight (drained weight, if applicable)
The correct format would then be, for example: Net Wt. 8 oz. (226 g). You can also specify count, as in: 20 chocolate candies.
Not sure how to set the size of your text for this?
Here’s a quick formula:
area of the PDP (width x height if rectangular or square; or 40% of product height x circumference if cylindrical)
Keep in mind that the required type must follow the Type Specifications in the Information Panel (IP) content and be at least the smallest size permitted based on the Primary Display Panel PDP) area:
If your PDP area is:
≤ 5 in² (32.26cm²)
> 5 in² (32.26cm²) but ≤ 25 in² (161.29cm²)
> 25 in² (161.29cm²) but ≤ 100 in² (645.16cm²)
> 100 in² (645.16cm²) but ≤ 400 in² (2,580.6cm²)
> 400 in² (2,580.6cm²)
Then your minimum type size is:
1/16 in (1.6mm)
1/8 in (3.2mm)
3/16 in (4.8mm)
1/4 in (6.4mm)
1/2 in (12.7mm)
PRODUCT DATES / LOT CODES
A.K.A. make the product, check the product, tag the product
This dating info gives your perishables a set standard for tracking and tagging. This is optional for most food products and can either be specified as “open dating” or “lot coding”.
“lot coding” helps you check and remove your products from retailers in the event that a certain batch isn’t up to par and must be recalled. This is in the short form of either numerals. symbols, or alphanumerical codes, and this helps you contain an otherwise large set of information (production date, time of packaging, who delivered your products to where, and so on).
“open dating” is suggested for all foods that spoil easily and helps your customer enjoy your offerings in the time frame when it is in its best condition. Noted as either in text (e.g. Sept 29) or numbers (09-29), this includes “pull date”, “quality assurance or freshness date”, “pack date” and “expiration date.” You would indicate pull date, quality assurance date, or pack date on labels to inform your retailers and consumers when the product was made or how long products should be offered for sale to ensure optimum quality. The expiration date tells your customer until when your product should spoil and when it can be consumed safely.
A.K.A. all the healthful goodness and food warnings for the conscious consumer
As mentioned in the IP section above, your confections’ nutritional content must be seen together with your ingredients list + name and address on either PDP or IP.
Take note of exemptions
You might not even need to put this on your labels. Check out the Nutrient Declaration section on the FDA website.
There are lots of variations here, in both info inclusion and presentation. For example, you can use a simplified format if your product contains insignificant amounts of eight or more of the mandatory nutrients (Calories, Total fat, Saturated fat, Trans fat, Cholesterol, Sodium, Total carbohydrate, Dietary fiber, Sugar, Protein, Vitamin A, Vitamin C, Calcium, and Iron), Just make sure that the five core nutrients (Calories, Total Fat, Sodium, Total carbohydrate, and Protein) appears on all “Nutrition Facts” panels regardless of the amount present or the format used.
You don’t have to specify fat cal, sat fat, and trans fat,
if the total fat in your product is less than 0.5 gram (1/2 gram) per serving and no claims are made about fat, fatty acid or cholesterol content. Replace this with a footnote that your product is “Not a significant source of trans fat.” Use at least 6-point size text for this. Other values and nutrients that you can omit and simply replace with the mentioned footnote are:
– Cholesterol < 2mg
– Sugar < 1g
– Vitamin A, Vitamin C, Calcium, Iron < 2% RDA
For amounts such as “less than 5 calories” or “less than 1 g”,
This can be stated as zero on your Nutrition Facts panel.
*If you’re looking for handy tools to help you complete your values on your confectionery labels, check out Nutrition Facts rounding amounts rules and Percent Daily Values calculations on the FDA website.
Done? Not quite. Apart from correct information, correct formatting must be used. How does this get presented on your labels? Scroll down for a quick guide below.
TEXT AND LINES CHECKLIST
Make sure that your Nutrition Facts content is enclosed in a box shape with at least a 1/2-point rule and must have sufficient contrast. Light print on dark background (instead of the standard dark print on light background) may be used as long as customers can still read what the box contains. Don’t do anything fancy—the box background must be neutral, with no unnecessary art elements.
Don’t mind the borders too much—there is no specific thickness required for the three horizontal rules that separate the main section.
Make the title “Nutrition Facts” the largest text in the panel (> 8-point) and format it so that this title extends the width of its box in Full Panel Format. More on that in the next section below.
Check your table headings (e.g. % Daily Value) and ensure that they are at least set at 6-point. Key nutrients should be set at at least 8-point.
Choose a font that is easy to read (The FDA’s examples are in well-loved Helvetica). You can use fonts that have tight kerning as long as all type requirements are still met. Think legible, not decorated.
Is your font tall enough? It’s ok to use type sizes at 6-point and above, or if you’re keen on using all uppercase text, as long as your text are at least 1/16 inch (1.6mm) tall.
FORMATTING (FULL PANEL FORMAT VS. SIDE-BY-SIDE FORMAT, TABULAR FORMAT VS. LINEAR FORMAT)
So, you’ve already finalised your labels and their dimensions… What if the whole table doesn’t fit with your current layout? Don’t worry, if you can’t use the Full Panel Format, you can always change to a Side-by-Side Format (footnote is to the right of the Nutrition Facts box) as long as the labeling area is greater than 40 in² (258.06cm²).
If you got less room that that, here are your options:
1) Remove the entire footnote; simply include just the Percent Daily Values footnote.
2) Use abbreviations: serv size, servings, fat cal, sat fat cal, sat fat, monounsat fat, polyunsat fat, cholest, total carb, fiber, sol fiber, insol fiber, sugar alc, other carb. If you shorten as “DV” on the table heading, the Percent Daily Values footnote should read “Percent Daily Values (DV)”, with “DV” in parentheses.
3) Change to Linear Format/text in a box if the Tabular Format won’t fit.
4) Move the Nutrition Facts label on any other panel on your packaging.
Now, what if you’ve got space but not enough VERTICAL space? If it’s less than 3 inches (76.2mm) you can go ahead and use the horizontal Tabular Format.
What are “labelling areas”?
These are any of the surfaces of your packaging that is visible when on shelf. But if you’re using cellophane for packaging your cakes and pastries, the cellophane windows on boxes (this include visible parts of cellophane bags) are only considered labelling areas ONLY if you place any labels on it. This include “non-required information” such as a discount blurb or a secondary price tag.
*Need references? Check out FDA Label Formats for correct examples.
NUTRITION CONTENT CLAIMS
A.K.A. words that you should use to qualify nutritional content
A Nutrition Content Claim is any word or statement that talks about the nutrient value of your product. Consumers are used to seeing stuff like this on labels: low fat, high in fiber, fat free. Sounds like a product benefit pitch, and really it is. You can certainly use a Nutrition Content Claim as a hook for promoting your “fat free” confectionery product, however make sure that it isn’t more than twice as prominent as your Statement of Identity. Also, words and statements shouldn’t be simply thrown around and put on your labels. There are specific words you can use.
So what are the correct terms?
Here’s the legit FDA-approved list of basic terms that you should use when describing the yummy goodness of your sweet sensations: free, low, reduced, fewer, high, less, more, lean, extra lean, good source, and light. Something good to note when talking about confectionery is that you can use “free”, as in “sodium-free”, if you had used less than 5mg of that ingredient per serving of food to make your products.
Nutrition labelling (your Nutrition Facts Panel) is required for nearly all claims. No nutrition claims can be made if no nutrition labelling is present, regardless of exemptions.
New regulation in gluten-free labelling: any product with a gluten-free claim must have LESS THAN 20 parts per million of gluten!
A.K.A. what happens when i eat that blueberry chocolate bar?
Confectionery creators could not only focus on flavor and presentation and may also do R&D and efforts to make something sweet, delicious, and “good for you”. A “health claim” is exactly that—it’s a food label message that describes the relationship between a food component, such as fat, calcium, or fiber, and a disease or health-related condition. FDA has approved various health claims based on extensive scientific evidence and defined conditions under which the claims can be used (e.g., sodium and hypertensionn, calcium and osteoporosis).
What’s the difference between the two?
Nutrient Content Claim indicates the nutritional value of the food. Health Claim describes the relationship between a food component and a disease or health-related condition. Make sure to define these clearly on your confectionery labels. Gluten-free, anyone?
*If you’re interested in the fine print, you can also check out Nutrition Content Claims on the FDA website.
PLEASE NOTE that this post does not constitute professional advice nor does it substitute for your reading and reviewing the applicable language from the FDA regulations or obtaining advice from the appropriate professional regarding what is and is not required by the FDA regulations. The reader of this article/blog is urged to read the FDA regulations and/or obtain the appropriate professional advice on the FDA regulations.