Minimum type size follows the principal display panel area.
Under 21 CFR § 101.7, the minimum letter height changes with the size of the principal display panel. These thresholds do not replace the separate legibility, contrast, spacing, and proportion requirements in the rule.
| Principal display panel area | Minimum letter height |
| 5 square inches or less | 1/16 inch |
| More than 5 through 25 square inches | 1/8 inch |
| More than 25 through 100 square inches | 3/16 inch |
| More than 100 through 400 square inches | 1/4 inch |
| More than 400 square inches | 1/2 inch |
Do not treat a size threshold as the whole review.The eCFR also addresses contrast, letter proportions, lower-case measurement, fractions, and increased size when the declaration is blown, embossed, or molded rather than printed.
Accuracy and package-content questions need the right source.
Section 101.7 states that the declaration must accurately reveal the quantity of food in the package, excluding wrappers and other packed-with material. It does not support replacing a product-specific assessment with a single, unsourced “allowable tolerance.”
Rule textStart with current eCFR
Use the current regulation to review the declaration’s quantity basis, location, format, legibility, and size requirements.
FDA guidanceUse official examples carefully
FDA’s Food Labeling Guide and metric policy organize common questions and examples, but the current regulation remains the governing starting point.
TestingSeparate labeling from test procedure
NIST Handbook 133 is a procedural guide for compliance testing of net-content statements. Use the applicable authority for the specific product and jurisdiction.
Label reviews need a clear source trail.
Guidance is rebuilding commercial CPG workflows with design partners. The practical foundation is a shared record of the current label, the product and package context, the source being reviewed, and the person accountable for the decision.
This page is educational, not a label approval or compliance determination. Guidance is in a commercial rebuild. This guide does not establish regulatory compliance, approve a label, replace a qualified reviewer, or represent a currently available automated labeling-compliance feature.
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Frequently asked questions
Does net quantity include the package or wrapper?
No. Section 101.7 says the declaration must accurately reveal the quantity of food in the package, exclusive of wrappers and other material packed with it. Check the current rule and applicable guidance for product-specific questions.
Does a small principal display panel remove the bottom-30-percent placement rule?
For a package with a principal display panel of 5 square inches or less, the rule provides an exception from the bottom-30-percent placement requirement when the declaration meets the other applicable requirements. It is not a general exemption from making the declaration.
Which unit is used for a liquid versus a solid food?
The rule generally uses fluid measure for liquids and weight for solid, semisolid, viscous, or mixed solid-and-liquid foods. Numerical count or dry measure applies in the circumstances described by the rule.
How is the minimum type size determined?
Minimum letter height is tied to the area of the principal display panel. Under § 101.7, the thresholds range from 1/16 inch on panels of 5 square inches or less to 1/2 inch when the panel area exceeds 400 square inches.