Hawaii cottage food label requirements

Hawaii calls it "homemade food," not cottage food, and the rules changed on August 24, 2025. That is when the Department of Health (DOH) amended HAR 11-50 to carry out Act 195 of 2024: pickled, fermented, and acidified plant foods came in, online and remote sales were written in, and for the first time you can sell wholesale to shops and restaurants. Most guides online still describe the 2017 version, which allowed in-person sales only. Treat anything that says "no internet sales" as out of date.

There are five situations where the answer flips and you do need a panel. They're below, after the part you actually came for.

The label Hawaii actually requires

HAR 11-50-3(c)(3) tells homemade food operators to "label all food in accordance with the requirements of section 11-50-35(c)," and 11-50-35(c)(4) lists what that means. Every prepackaged homemade food product you sell in Hawaii needs:

1. The Hawaii disclaimer, word for word. Wording below.
2. The common name of the food, "or, if no common name exists, an adequately descriptive identity statement."
3. The ingredient list, in descending order by weight, if the food is made from two or more ingredients. Sub-ingredients count; the rule says "ingredients and subingredients." If your chocolate chips contain soy lecithin, that has to show up.
4. Allergen declaration. The rule requires "notification of the presence of major food allergens," and DOH's fact sheet lists the nine: milk, eggs, fish, shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Sesame joined the list under the FASTER Act on January 1, 2023. You can declare them parenthetically inside the ingredient list or in a separate "Contains" statement. Tree nuts, fish, and shellfish must be named by species — "macadamia nuts," not "tree nuts."
5. The name and contact information of the producer. Hawaii says "contact information," not "address." DOH's own sample label uses a business name, a website, and an email address.

Net weight is not on Hawaii's list. It becomes required under 21 CFR 101.105 the moment you leave homemade food, so most people add it from day one rather than redesign later.

The exact disclaimer wording

Made in a home kitchen not routinely inspected by the Department of Health

That is HAR 11-50-35(c)(4)(A). The rule sets no minimum type size and no placement requirement. DOH's sample label adds a period at the end; the rule text does not include one.

Don't paraphrase it, don't swap "home kitchen" for "cottage food operation," and don't drop "routinely." Inspectors and market managers read this string literally, and so do the restaurants and shops that are now allowed to carry you: a restaurant putting your product on its menu must have written disclosure that it is a homemade food, and your label must be available to any patron who asks.

Where a Nutrition Facts panel becomes required

No US state requires a full Nutrition Facts panel on cottage food products. You need one when:

1. You make a nutrient content claim — "high protein," "low sugar," "keto," "sugar free." Any of these obligates the panel that substantiates it.
2. You make a health claim — connecting your food to a disease or health condition.
3. You outgrow your state's cottage food cap and move to a commercial kitchen. At that point you are a regular food manufacturer and the cottage exemption is gone.
4. You sell wholesale or into retail. Cottage exemptions are almost universally direct-to-consumer only.
5. You sell on Amazon or another marketplace that requires a panel. Amazon's requirement is contractual, not legal, and it does not care what your state says.

Hawaii has no cap, and since August 2025 it allows wholesale, so triggers three and four don't end the exemption by themselves. What they do is put your jar on a shelf next to commercially made products, and the retailer or distributor often asks for a panel as a condition of carrying you. DOH's fact sheet adds a warning worth reading twice: FDA "does not recognize HMF products as an approved source," which is why a licensed food establishment that buys from you takes on its own compliance questions.

Trigger one catches more people than the other four combined, and it catches them somewhere they don't expect. Under 21 CFR 101.9(j)(18), the exemption is void if the claim appears in advertising — not just on the package. Calling your granola "high protein" in an Instagram caption is enough to require the panel on the bag.

What you can and can't make in Hawaii

Hawaii uses an exclusion model built on a definition. Under HAR 11-50-2, "homemade food products" means any food that is not time/temperature controlled for safety, "produced or packaged in a home kitchen that does not include dried meats or seafood," plus one special category: foods of plant origin that are pickled, fermented, or acidified, with a pH of 4.2 or less or a water activity below 0.88, excluding melons.

Allowed, per the rule and DOH's fact sheet:

Prohibited:

Honey is its own program. DOH says the 2025 homemade food changes do not apply to home-based honey producers, who stay under HRS 328-79 and may not sell to a wholesaler.

If your product is on that prohibited list, cottage food law is not your path. You'll need a licensed commercial or shared-use kitchen with a DOH food establishment permit, and once you're operating out of one you're a food manufacturer under federal law — which means full labeling, including a Nutrition Facts panel unless you qualify for the small business exemption below.

Where you can sell

HAR 11-50-3(c)(4) is the operative text. Homemade food may be distributed "directly to the consumer, whether in person or remotely, including by telephone or the internet," or through "an agent of the homemade food operator or a third-party vendor such as a food establishment," and "delivered to the consumer by the homemade food operator, an agent of the homemade food operator or a third-party vendor such as a food establishment, by mail, or shipping." Juice is the exception: direct sale only. Hand-pounded poi, which shares the exemption, is also direct sale only.

On state lines, the rule is silent. It draws no geographic boundary the way Texas or California do, and DOH's fact sheet does not address it. We won't tell you Hawaii bans it, because the rule doesn't say so. But the federal question is real.

Interstate is a hard no everywhere, and the reason is jurisdictional rather than arbitrary: the moment a product crosses a state line it enters interstate commerce and FDA has authority over the whole operation that made it. Your state's cottage food exemption cannot exempt you from federal law. If you ship to one customer in another state, you have stepped outside the exemption for that shipment.

The cap, the permit, and the training

The exemption in 11-50-3(c) is conditional. You stay exempt from the rest of chapter 11-50 only while you hold the food safety certification, keep the handwashing sink available, label correctly, and distribute through the channels the rule lists. Violate one of those "special conditions" and the violation counts as a violation of the chapter.

One more change is on the way. In 2026 the Legislature passed SB 3302, directing DOH to write rules that treat a "farm kitchen" on agricultural land the same as a home kitchen for homemade food, without a commercial food establishment permit. It took effect on approval, but the DOH rules it calls for had not been published as of this review. If you cook on a farm, watch for them.

When you outgrow cottage food

With no cap, nobody outgrows Hawaii homemade food by volume. Any of these ends the exemption:

• You want to make jerky, dried fish, or anything else with meat or seafood.
• You want to can anything other than jam or jelly, or vacuum-seal anything.
• You want to ship to the mainland as a real sales channel.
• You want to say "high protein" on the bag.
• A distributor says yes and asks for a panel.

Whichever one gets you first, the day after it happens you are a food manufacturer, and food manufacturers label under 21 CFR 101.9. Your label now needs a Nutrition Facts panel with a serving size pulled from the RACC table in 21 CFR 101.12 — not a serving size you chose.

You might still be exempt, even out of a commercial kitchen

21 CFR 101.9(j)(18) exempts small businesses from the Nutrition Facts requirement if you have fewer than 100 full-time equivalent employees and sell fewer than 100,000 units in the US in a 12-month period. You have to file an annual notice with FDA to claim it. FDA is blunt about the follow-up: "FDA DOES NOT NOTIFY FIRMS WHEN IT IS TIME TO FILE A NOTICE." That's on you.

There's a smaller carve-out under the same section: if you're not an importer, have fewer than 10 full-time equivalent employees, and sell fewer than 10,000 units a year, you don't have to file anything at all.

And the exemption is void — filed or not — for any product carrying a nutrient content claim, a health claim, or other nutrition information, whether that appears on the label, in labeling, or in advertising. See FDA's labeling guidance for the full text.

If you've hit one of the triggers and need the panel itself, Nutrillius builds an FDA-compliant Nutrition Facts panel from your recipe in about a minute — $39 one time, no subscription. That's against $1,609–$1,724 for a single lab-analyzed sample at Medallion Labs, or $195 and a two-to-four week wait through a university extension lab.

Verify this yourself

Cottage food law changes most legislative sessions, and Hawaii has moved twice in two years: Act 195 in 2024, the HAR 11-50 rewrite effective August 24, 2025, and farm-kitchen rules still to come. Before you print labels, check the current rules with the agency directly:

• Hawaii Department of Health, Food Safety Branch — Homemade Food Products fact sheet (PDF)
• HAR 11-50-3(c) and 11-50-35(c)(4): Hawaii Administrative Rules, Title 11, Chapter 50, as amended August 2025 (PDF)
• DOH news release on the 2025 Food Safety Code update
• Act 195, Session Laws of Hawaii 2024 (HB 2144)

This page was last reviewed October 30, 2026. If you're reading it much later than that, verify the disclaimer wording and the sales-channel rules before you rely on either.