21 CFR 101.9(d)(11)(iii)
Tabular nutrition facts label format
The tabular display is a space concession, not a design choice. 21 CFR 101.9(d)(11)(iii) makes it available only when there is not roughly three inches of continuous vertical space for the standard panel up to and including the potassium line. The heading block sits at the left and the nutrients run in columns beside it, so the panel is wide and shallow instead of tall.
What the regulation actually says
“If there is not sufficient continuous vertical space (i.e., approximately 3 in) to accommodate the required components of the nutrition label up to and including the mandatory declaration of potassium, the nutrition label may be presented in a tabular display.”
What rules it out: A package that can accommodate the standard vertical panel. If three inches of continuous vertical space exists anywhere on a panel that can bear labelling, the tabular display is not available to you no matter how much better it suits the artwork.
A tabular panel, rendered
Maple pecan granola, whose long shallow sleeve is exactly the package shape that fails the three-inch test. Both panels below carry the same nutrient values from the same recipe — the tabular 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.
How to establish that you may use the tabular format
- Identify every panel of the package that can bear labelling, and measure the continuous vertical space on each.
- If none of them offers roughly three inches up to and including the potassium line, the tabular display is available.
- Record the measurement. The test is about the package, and you may be asked to show your working.
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.
| Element | Minimum | Paragraph |
|---|---|---|
| The word “Calories” | 10 pt bold | 101.9(d)(2)(iii) |
| The calories numeral | 14 pt bold | 101.9(d)(2)(iii) |
| Servings per container | 9 pt | 101.9(d)(3)(i) |
| “Serving size” and its amount | 9 pt bold | 101.9(d)(3)(ii) |
| Nutrient rows | 8 pt | 101.9(d)(2)(iii) |
| Headings, subheadings and the footnote | 6 pt | 101.9(d)(2)(iii) |
| Leading between nutrient rows | 4 pt | 101.9(d)(2)(ii)(C) |
Practical notes
- The calories type-size minimums relax to 10 point for the word and 14 point for the numeral in a tabular display — 101.9(d)(2)(iii).
- 'Serving size' may drop to 9 point in the tabular display — 101.9(d)(3)(ii).
- This is the format for wide, shallow packages: sleeves, trays, tubs and long boxes.
Frequently asked questions
- When can I use a tabular nutrition facts label?
- Only when the standard vertical panel will not fit. 21 CFR 101.9(d)(11)(iii) states the test as “not sufficient continuous vertical space (i.e., approximately 3 in) to accommodate the required components of the nutrition label up to and including the mandatory declaration of potassium”. Meet that test and the tabular display is permitted; fail it and the standard vertical format is mandatory.
- Do the type sizes change in a tabular display?
- Yes, in three places. “Calories” drops from 16 pt to 10 pt and its numeral from 22 pt to 14 pt under 101.9(d)(2)(iii). The servings statement drops from 10 pt to 9 pt under 101.9(d)(3)(i), and “Serving size” does the same under 101.9(d)(3)(ii). The 8 pt floor on nutrient rows and the 6 pt floor on headings and the footnote do not move.
- Can a tabular label leave out the full footnote?
- Not on the strength of being tabular. The abbreviated “% DV = % Daily Value” footnote in 101.9(j)(13)(i) is tied to small packages — 40 square inches or less — and to the simplified format in 101.9(f)(5), not to the tabular display itself. A tabular label on a large package carries the full daily-diet footnote.
The other five formats
Every format is an answer to a different constraint. If the tabular display does not fit your package, one of these will.
| Format | When it applies |
|---|---|
| standard vertical | The default. Use it unless the package physically cannot fit roughly three inches of continuous vertical space. |
| linear | One running string of text. The most constrained format there is, and the hardest to qualify for. |
| dual-column | Per serving and per container side by side. Required, not optional, on a lot of the sizes small producers actually sell. |
| simplified | A short panel for foods that are mostly nothing — sugar, salt, spices, oils, hard candy. |
| small package | A compressed tabular panel for packages of 40 square inches or less — the jam jar, the single-serve bar, the sample pack. |
Keep going
- six FDA label formatsStandard vertical, tabular, linear, dual-column, simplified and small package — when each one is allowed.
- nutrition label makerThe same engine with the arithmetic opened up line by line, so you can see where every gram came from.
- serving size referenceAll 146 reference amounts customarily consumed from 21 CFR 101.12(b), the table that decides your serving size.
- FDA rounding rulesEvery rounding increment in 21 CFR 101.9, quoted, with worked examples and an interactive check.