LabelMath

21 CFR 101.9(d), (e), (f) and (j)(13)

FDA nutrition label formats

There are six Nutrition Facts formats, and five of them are exceptions you have to qualify for. The standard vertical panel is the default; the tabular and linear displays are space concessions; dual-column is mandatory in one package-size band; simplified is for foods that are mostly nothing; and the small-package display is for 40 square inches or less. Each is rendered below from the same recipe.

The decision, in one table

The six FDA nutrition label formats and their conditions
FormatWhen it appliesParagraph
standard verticalAlways available. Every other format is an exception to this one.101.9(d)
tabularAvailable when there is not roughly three inches of continuous vertical space for the standard panel up to and including the potassium line.101.9(d)(11)(iii)
linearOnly for packages with less than 12 square inches of labelling surface, and only when a tabular display will not fit either.101.9(j)(13)(ii)(A)(2)
dual-columnRequired when a package contains at least 200% and up to and including 300% of the reference amount customarily consumed — the range where people plausibly eat the whole thing in one sitting.101.9(e)(6)(i), (b)(12)(i)
simplifiedAvailable when the food contains insignificant amounts of eight or more of the fifteen listed nutrients.101.9(f)
small packageAvailable when the total surface area available to bear labelling is 40 square inches or less. Packages under 12 square inches with no nutrition claims may be exempt from nutrition labelling altogether under 101.9(j)(13)(i).101.9(j)(13)(ii)(A)(1)

The same cookie, six ways

One recipe — 36 chocolate chip cookies — rendered in every format. The nutrient values are identical in all six; what changes is what fits, what may be abbreviated and what may be left out.

How to choose in practice

Work down the list. Does the standard vertical panel fit on a panel of the package with roughly three inches of continuous vertical space? Use it. If not, is there room for a tabular display? Use that. Only if neither fits, and the labelling surface is under twelve square inches, does the linear string become available.

Then check the two overrides. If the package holds between 200 and 300 percent of the reference amount for your category, dual-column is mandatory regardless of what else fits — work out your reference amount from the serving size reference. And if eight or more of the fifteen listed nutrients are present in insignificant amounts, the simplified format is available and will make a much cleaner label.

Frequently asked questions

How many Nutrition Facts label formats are there?
Six that a small producer will meet: standard vertical, tabular, linear, dual-column, simplified and the small-package display. The standard vertical in 21 CFR 101.9(d) is the default and every other one is an exception with a stated condition — a space constraint, a package size, a nutrient profile or a container that holds a particular multiple of the reference amount.
Can I just pick the format I like the look of?
No. Each alternative format has a condition in the regulation and you have to meet it. The tabular display needs the standard panel not to fit in roughly three inches of continuous vertical space. The linear string additionally needs the tabular display not to fit. The dual-column is not a choice at all — it is mandatory in a defined package-size band.
Which format is mandatory rather than optional?
Dual-column. 21 CFR 101.9(b)(12)(i) requires it when a package contains at least 200 percent and up to and including 300 percent of the reference amount customarily consumed — the sizes people plausibly finish in one sitting. Below 200 percent the whole container is a single serving; above 300 percent normal per-serving labelling applies.
Do the type-size minimums change between formats?
Yes, and it is one of the few places the regulation relaxes. On a standard panel 'Calories' must be at least 16 point with a 22 point numeral. In the tabular displays and the linear small-package display those drop to 10 point and 14 point, and 'Serving size' and the servings statement drop from 10 point to 9 point. Everything else — 8 point nutrient rows, 6 point headings and footnote — holds.

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