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Guide April 16, 2026 · Guidance Team

• ✓ Ensure your Nutrition Facts label is accurate from day one, reflecting your exact product formulation.
• ✓ Choose between lab analysis or database calculation for nutrition data based on your product's complexity.
• ✓ Correctly determine serving sizes using FDA Reference Amounts Customarily Consumed (RACCs).
• ✓ Update your labels promptly with any ingredient, supplier, or recipe changes to maintain compliance.

Understanding the Basics: What the FDA Requires

The Nutrition Facts panel isn't just a suggestion; it's a legal document. The FDA dictates specific nutrients you must declare, including calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrates, dietary fiber, total sugars, added sugars, protein, Vitamin D, calcium, iron, and potassium. You also need to list serving size and servings per container. Pay close attention to the format, font size, and order of nutrients. For example, 'Added Sugars' must be indented under 'Total Sugars'. Any deviation can result in a warning letter or, worse, a recall. Your label needs to be precise and reflect exactly what's in your package.

Calculating Nutrition Data: Your Options

You have two primary ways to generate your nutrition data: laboratory analysis or database analysis. Lab analysis involves sending your finished product to a certified lab, which provides precise nutrient values. This is often necessary for novel ingredients or complex formulations, costing anywhere from $300 to $700 per SKU. Database analysis uses software like Genesis R&D or USDA's SR Legacy database to calculate values based on your ingredient list and recipe. This is generally more cost-effective for simpler products with common ingredients. Whichever method you choose, ensure the data is accurate and defensible if the FDA comes knocking. Don't guess; verify.

Serving Size and Servings Per Container: Getting It Right

Determining your product's serving size is crucial and often misunderstood. The FDA provides 'Reference Amounts Customarily Consumed' (RACCs) for various food categories. Your serving size must be the RACC or a household measure closest to it. For example, the RACC for chips is 1 ounce (28g). If your bag is 3 ounces, you'll declare three servings per container. For single-serving packages that contain between 200% and 300% of the RACC (e.g., a 2.5 oz cookie where RACC is 1 oz), you must declare the entire package as a single serving. Incorrect serving sizes can misrepresent calorie and nutrient intake, leading to consumer complaints and compliance issues.

Ingredient Statements and Allergen Declarations

Beyond the Nutrition Facts panel, your ingredient statement and allergen declaration are equally vital. List all ingredients in descending order by weight, including sub-ingredients (e.g., 'chocolate chips [sugar, cocoa mass...]'). The Food Allergen Labeling and Consumer Protection Act (FALCPA) requires clear declaration of the eight major food allergens: milk, eggs, peanuts, tree nuts, soy, wheat, fish, and shellfish. You can use a 'Contains' statement immediately after the ingredient list (e.g., 'Contains: Milk, Soy') or identify allergens within the ingredient list itself. If your co-packer handles shared lines, a 'May Contain' statement for potential cross-contact is good practice.

Maintaining Accuracy with Recipe Changes and COGS

Your Nutrition Facts label is a snapshot in time. Any change to your recipe, ingredient supplier, or even a minor formulation tweak can alter nutrient values. This means your label can quickly become inaccurate. If you switch from one organic sugar supplier to another, even if both are 'organic cane sugar,' their specific nutritional profiles might vary enough to impact your label. This is where a platform like Guidance becomes invaluable. Your Bill of Materials (BOM) in Guidance automatically updates ingredient costs and can be tied to nutritional data, alerting you to potential label shifts when sourcing changes or new suppliers are onboarded. This proactive approach prevents costly relabeling or recalls.

Common Pitfalls and How to Avoid Them

Many brands stumble on rounding rules. The FDA has specific guidelines for rounding calories, fats, sodium, and other nutrients. For instance, if your product has 4 calories per serving, you must declare 0 calories. If it's 45 calories, you declare 45. If it's 52 calories, you declare 50. Misinterpreting these rules can lead to inaccurate labels. Another pitfall is making nutrient content claims (e.g., 'low fat,' 'high fiber') or health claims without meeting the strict FDA criteria. Always verify any claims with the FDA regulations. An inaccurate label isn't just a fine; it erodes consumer trust and can trigger expensive product recalls.

See How Guidance Handles This

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