Do I need a Nutrition Facts label to sell my food product?

If you're packaging food to sell to the public — at a shop, at a farmers market with a shelf-stable product, wholesale to a store, or online — the short answer is almost always yes. Federal law requires most packaged foods to carry a Nutrition Facts panel, a complete ingredient statement, and an allergen declaration before they can be offered for sale. The exemptions are real, but they're narrower than most new sellers expect, and a few common assumptions about "small batch" or "homemade" don't actually hold up under the regulation.

When a label is required

Any food in a sealed package offered for retail sale generally needs full nutrition labeling under FDA rules (21 CFR 101.9). That covers jams, sauces, baked goods, snacks, sauces, and spice blends — anything sold in a container the customer takes home, regardless of channel.

• Retail (farmers market, your own storefront, a pop-up): if the product is pre-packaged before the point of sale, it needs a label. Food scooped or weighed to order in front of the customer is generally treated differently — see the note below.
• Wholesale (selling into a grocery store, co-op, or specialty shop): the store's buyer will almost always require a compliant label before they'll accept the product, independent of whether FDA would otherwise require one for your specific volume.
• Online / marketplace (your own site, Etsy, Amazon): platforms increasingly require a label image or PDF at listing time, and interstate shipping puts you squarely under federal jurisdiction rather than a single state's cottage-food rules.

Selling the same cookies loose at a bake sale is different from selling them in a sealed bag on a shelf. The package is what triggers the labeling requirement — not the recipe, the kitchen, or the size of the business.

The small-business exemption

Some small businesses do qualify for an exemption from the Nutrition Facts panel requirement, but it's two distinct, narrow exemptions — not a general "small batch" carve-out — and each has its own threshold:

1. Retailer gross-sales exemption (21 CFR 101.9(j)(1)): a person or business with total annual gross sales of not more than $500,000, or with annual gross sales of food to consumers of not more than $50,000, doesn't have to provide nutrition labeling for the foods they sell. No notice to FDA is required to claim this one.
2. Low-volume product exemption (21 CFR 101.9(j)(18)): a product sold in fewer than 100,000 units in the U.S. in a 12-month period, made by a business with fewer than 100 full-time equivalent employees, can be exempted product-by-product — but only if you file an annual notice with FDA claiming the exemption, with a responsible individual certifying the numbers.

Both exemptions disappear the instant you make a nutrient content claim (like "low fat" or "high fiber") or a health claim on the package — at that point full nutrition labeling is required regardless of size. And neither exemption touches the other mandatory information: product name, net quantity of contents, ingredient list, allergen declaration, and manufacturer name and address are still required no matter how small the business is. In practice, most sellers who plan to sell beyond a single farmers-market table, or who expect to grow, choose to label from day one rather than track two separate thresholds and refile a notice every year.

What a compliant label needs

At minimum, a compliant package carries:

• Nutrition Facts panel in the 2016 format (21 CFR 101.9) — calories, serving size based on FDA's reference amounts, and the full nutrient list with %DV.
• Ingredient statement, listed in descending order by weight, including sub-ingredients of any component ingredient.
• Allergen "Contains" declaration covering the nine major allergens: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame.
• Net quantity of contents in both metric and U.S. customary units.
• Business name and address of the manufacturer, packer, or distributor.

The Nutrition Facts panel itself is the most regulated piece — its fonts, rule weights, and row order are fixed by the CFR, not a design choice — so it's worth generating it from your actual ingredient list and serving size rather than approximating one in a design tool.

How to make yours

Start from your ingredient list with real gram weights per serving, not volume measures — nutrition math is done by weight. From there you need the per-ingredient nutrient data (USDA's FoodData Central is the standard free source), a defined serving size, and your declared allergens. CompliantLabel's builder does the USDA lookup, the %DV math, and the FDA-format rendering for you, and lets you preview the exact label — watermarked — before you ever create an account.