What am I required to put on the label of a value-added food product?

All food products that are intended for public sale must meet a minimum set of labeling requirements. In essence, the minimum label requirements are:

1. name and contact information for the manufacturer, distributor or packer.
2. net weight of the contents
3. product name
4. listing of ingredients

A nutrition label is required on most food products, but not all. The nutrition label is not required for plain coffee and tea; some spices, flavorings and other food that contain no significant amounts of nutrients; ready-to-eat food prepared primarily on site, such as deli and bakery items; donated food items; vended food and bulk food that is not distributed to consumers in bulk form. A nutrition label is also not required on foods produced by entities that meet a specific criteria as a "small business."

Small businesses are defined by the Food and Drug Administration as a food business with food sales of less than $50,000 a year or total sales of less than $500,000. To apply for a small business exemption, the business must employ less than 100 employees, produce less than 100,000 units and make no nutritional claims. However, if a product claims to have any nutrient content, or makes any health claims, nutritional labeling must be provided regardless of production size, number of employees or place of manufacturing. A small business exemption form can be obtained in Tennessee from the Nashville District Food and Drug Administration office. Alternate nutrition labeling regulations apply to the following products; foods for children less than 2 years of age; exported game meats; shell eggs; foods sold from bulk containers; unit containers in a multi-unit, retail package; packaged single-ingredient; and fish. (See Appendix B for a sample A Small Business Food Labeling Exemption Notice application.)

Also exempted from nutritional labeling are foods in small packages (less than 12 square inches of total package area), unless they make a nutrition claim. However, FDA-regulated products must carry a telephone number or address that consumers can use to get required nutrition information.

A properly worded and presented nutrition label is required on all other packaged foods. When required, the nutrition label panel is titled "Nutrition Facts" and must include mandatory nutrient information expressed as total amount per serving size and as a percent of the daily value (%DV). The percent of the daily value (%DV) must be footnoted on the label with the statement "Percent Daily Values" are based on a 2,000-calorie diet.

After a food product label has been written and designed, it is recommended that it be submitted for review to the Regulatory Services, Food and Dairy Section, Tennessee Department of Agriculture. This step is not required by law; however, this is a service that can be very helpful to the food business.

Additional information for each of the four minimum label requirements is presented below.

1. The name, street address, city, state and zip code of either the manufacturer, packer or distributor.
• The street address of a firm may be omitted if the firm is listed in a current telephone directory.
• If the food is not manufactured by the person or company whose name appears on the label, the name must be qualified by "Manufactured for," "Distributed by" or a similar expression.
  
2. An accurate statement of the net weight of food in the package.
• The net weight of a product is the weight of the food in the package. The weight of the container or wrapper is not included. For some products packed in liquids, such as mushrooms, the fluid is considered part of the packaging; therefore, the drained weight should be used. For most canned foods, liquid is considered part of the product
• The net weight must be expressed in both metric (grams, kilograms, milliliters, liters) and in U.S. Customary System (ounces, pounds, fluid ounces). An exception to this regulation is that dual labeling is not required for products that are random packed, i.e., similar items that do not weigh the same, such as produce and products in meat cases or delis.
• The quantity of content declared must appear on the "Principal Display Panel," the portion of the label most likely to be seen by the consumers, in lines generally parallel to the base of the package when displayed.
• The information must appear in the lower 30 percent of the panel and should be a distinct item.
• The type size used for the net weight statement is determined as a percentage of the size of the "Principal Display Panel."
  
3. The common or usual name of the food.
• The common or usual name of a food must appear on the "Principal Display Panel," in bold type and in lines generally parallel to the base of the package as it is displayed.
• The form of the product must also be included "sliced," "whole" or "chopped" (or other style) unless shown by a picture or unless the product is visible through the container.
  
4. The ingredients in the food.
• The ingredients in all processed, packaged foods, including standardized food, must be listed by their common names and in the order of their predominance by weight.
• Ingredients are not the chemical composition, but rather a listing of the individual foods that come together to make the final product.
• If an ingredient is the characterizing element of the food, such as crab in crab meat, the percent of that ingredient may be required to be part of the name of that food on the label.

Additional information on preparing and marketing value-added food products is available in two UT Extension publications:

1. "Adding Value to Tennessee Agriculture Through Commercial Food-Processing Enterprises" at http://www.utextension.utk.edu/publications/pbfiles/pb1710.pdf
   
2. "Getting Started in a Food Manufacturing Business in Tennessee" at http://www.utextension.utk.edu/publications/pbfiles/pb1399.pdf