LabelMath

21 CFR 101.9(j)(13)(ii)(A)(1)

Small package nutrition facts label

The small-package display is a compressed tabular panel for products whose total surface area available to bear labelling is 40 square inches or less — the jam jar, the single-serve bar, the sample pack. 21 CFR 101.9(j)(13)(ii)(A)(1) lets these labels modify the requirements of paragraphs (c) through (f) and (i), which is a wider licence than any other format gets.

What the regulation actually says

Foods in packages that have a total surface area available to bear labeling of 40 or less square inches may modify the requirements of paragraphs (c) through (f) and (i) of this section…
21 CFR 101.9(j)(13)(ii)(A)(1)

What rules it out: More than 40 square inches of total labelling surface. Note that the test is total surface available to bear labelling across the whole package, not the area of the panel you intend to print the label on.

A small package panel, rendered

The same strawberry jam, this time in its 4 oz jar, where the whole label surface is under 40 square inches. Both panels below carry the same nutrient values from the same recipe — the small package display on the left and the standard vertical panel on the right — so you can see exactly what this format changes and what it leaves alone.

small package format Nutrition Facts panel for Strawberry JamNutrition Facts55 servings per containerServing size 1 tbsp (21g)Calories50* % DV = % Daily Value% DV*Total Fat0g0%Saturated Fat 0g0%TransFat 0gCholesterol0mg0%Sodium0mg0%Total Carbohydrate13g5%Dietary Fiber 0g0%Total Sugars 12gIncludes 11g Added Sugars22%Protein0gVitamin D 0% • Calcium 0%Iron 0% • Potassium 0%
small packageStrawberry Jam, 55 servings. Build this from your own recipe and export it as PNG, SVG or print-resolution PDF.
Standard vertical Nutrition Facts panel for Strawberry JamNutrition Facts55 servings per containerServing size1 tbsp (21g)Amount per servingCalories50% Daily Value*Total Fat0g0%Saturated Fat 0g0%TransFat 0gCholesterol0mg0%Sodium0mg0%Total Carbohydrate13g5%Dietary Fiber 0g0%Total Sugars 12gIncludes 11g Added Sugars22%Protein0gVitamin D 0mcg0%Calcium 3mg0%Iron 0.1mg0%Potassium 27mg0%* The % Daily Value tells you how much a nutrient in aserving of food contributes to a daily diet. 2,000 calories aday is used for general nutrition advice.
Standard vertical — the same numbers in the default format, for comparison.

How to establish that you may use the small package format

  1. Add up the total surface area of the package that is available to bear labelling — every panel, not just the front.
  2. At 40 square inches or less, the small-package modifications in 101.9(j)(13)(ii)(A)(1) are available.
  3. Under 12 square inches, check 101.9(j)(13)(i) as well: you may be exempt from nutrition labelling entirely, provided you make no nutrient content or health claim.

Type-size minimums for this format

Type size is where the alternative formats differ most from the default, and it is the part a designer is most likely to get wrong. These are floors, not targets.

Minimum type sizes for the small package nutrition label format
ElementMinimumParagraph
The word “Calories”10 pt bold101.9(d)(2)(iii)
The calories numeral14 pt bold101.9(d)(2)(iii)
Servings per container9 pt101.9(d)(3)(i)
“Serving size” and its amount9 pt bold101.9(d)(3)(ii)
Abbreviated footnote “% DV = % Daily Value”6 pt101.9(j)(13)(i)
Nutrient rows8 pt101.9(d)(2)(iii)
Headings, subheadings and the footnote6 pt101.9(d)(2)(iii)
Leading between nutrient rows4 pt101.9(d)(2)(ii)(C)

Practical notes

  • Quantitative weights for vitamin D, calcium, iron and potassium are not required on these labels — only the % Daily Value — 101.9(c)(8)(ii).
  • Servings per container and 'Serving size' may drop to 9 point, and calories to 10 point with a 14 point numeral — 101.9(d)(3) and (d)(2)(iii).
  • The footnote may be reduced to '% DV = % Daily Value' — 101.9(j)(13)(i).

Frequently asked questions

What counts as a small package for nutrition labelling?
Forty square inches or less of total surface area available to bear labelling, under 21 CFR 101.9(j)(13)(ii)(A)(1). A 4 oz jam jar with a 2.5 in wrap-around label about 2 in tall is roughly 20 square inches and qualifies comfortably. The measurement covers the whole package surface that could carry printing, not the area of your artwork.
Can I leave the milligram amounts off the vitamins and minerals?
Yes. 21 CFR 101.9(c)(8)(ii) lets labels on packages of 40 square inches or less declare only the percent Daily Value for vitamin D, calcium, iron and potassium, dropping the quantitative micrograms and milligrams. That is usually the single biggest space saving available on a small label.
Is a small package automatically exempt from nutrition labelling?
Only below 12 square inches, and only conditionally. 21 CFR 101.9(j)(13)(i) grants that exemption when no nutrient content claim or health claim is made and the label gives an address or telephone number for obtaining the nutrition information. Between 12 and 40 square inches you must label — you simply get the compressed format and the shortened footnote.

The other five formats

Every format is an answer to a different constraint. If the small package display does not fit your package, one of these will.

The other five FDA nutrition label formats
FormatWhen it applies
standard verticalThe default. Use it unless the package physically cannot fit roughly three inches of continuous vertical space.
tabularFor packages with no tall panel: the heading block sits on the left and the nutrients run in columns beside it.
linearOne running string of text. The most constrained format there is, and the hardest to qualify for.
dual-columnPer serving and per container side by side. Required, not optional, on a lot of the sizes small producers actually sell.
simplifiedA short panel for foods that are mostly nothing — sugar, salt, spices, oils, hard candy.

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