Illinois cottage food label requirements

Illinois rewrote this law with the Home-to-Market Act, Public Act 102-633, effective January 1, 2022, and amended it again with Public Act 103-903, effective January 1, 2025. The rewrite removed the old dollar cap, replaced the narrow approved-foods list with a prohibited list, and moved registration to your local health department. Older guides that quote a $36,000 limit or a list of permitted baked goods are describing a law that no longer exists.

The label Illinois actually requires

Section 4(b)(7) of 410 ILCS 625 says food packaging "shall be affixed with a prominent label" containing:

1. The name of the cottage food operation and the unit of local government where it's located. Your business name plus the municipality or county.
2. Your registration number from the local health department, along with the name of the municipality or county where you registered. This one is distinct to Illinois — the number goes on every package.
3. The common or usual name of the food product. "Blueberry scones," not "Morning Magic."
4. All ingredients, including any color, artificial flavor, and preservative, listed in descending order by predominance of weight, using common or usual names. Sub-ingredients count.
5. The date the product was processed. Illinois requires a full date — month, day, year — per the state's cottage food guide. Most states don't ask for this and it's the element people forget.
6. Allergen labeling as specified under federal labeling requirements. Nine allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans, and sesame. Sesame was added by the FASTER Act effective January 1, 2023. Declare them parenthetically inside the ingredient list or in a "Contains" statement, and name tree nuts by species — "pecans," not "tree nuts."
7. The Illinois disclaimer, word for word, in prominent lettering.

The net weight or net volume is not in the statute's list, but the Cottage Food Guide — developed by IDPH and published by University of Illinois Extension — includes it in the required elements. Attribute it correctly and put it on anyway: it comes from agency guidance rather than 410 ILCS 625/4, it's federally required the moment you leave cottage food, and it costs you nothing.

The exact disclaimer wording

This product was produced in a home kitchen not inspected by a health department that may also process common food allergens. If you have safety concerns, contact your local health department.

Two sentences. Both of them. This is the single most-truncated string in Illinois cottage food — a large share of the label templates online drop the second sentence, and it is in the statute. Section 4(b)(7)(E) requires it "in prominent lettering." The statute sets no minimum point size, which means "prominent" is the standard your local health department will read literally, so don't bury it.

There's a second requirement most templates miss, and it's broader than bulk sales. Section 4(b)(10) requires that at the point of sale, notice be provided in a prominent location. At a physical display that notice is a placard. Online, it's a message on your sales interface at the point of sale. So selling sealed, fully labeled packages over the internet does not get you out of it — you still owe the notice. The string:

This product was produced in a home kitchen not inspected by a health department that may also process common food allergens.

That's the statutory wording, with no commas. The Cottage Food Guide prints a comma variant of it; the statute controls. Don't paraphrase either version, don't shorten them to "made in a home kitchen," and don't merge them.

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.

Illinois has no cap, so trigger three won't fire on revenue here. What bites instead is trigger four: 410 ILCS 625/4 requires that products be sold "directly to consumers for their own consumption and not for resale," and IDPH's guide is explicit that wholesale and retail resale are prohibited. The first grocery buyer or coffee shop that wants to stock you is the day you leave the program. Trigger one runs a close second, and trigger five is common because the law permits online sales, which pulls people toward marketplaces.

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 Illinois

Illinois uses an exclusion model, and has since January 1, 2018: all food and drink are permitted except what the statute specifically prohibits. If an item isn't on the prohibited list below, it's allowed. That's the opposite of how most states work, and it's why Illinois cottage food covers hot sauce, dry mixes, and shelf-stable canned goods that a Florida or Georgia operator can't touch.

Some categories carry extra conditions rather than a ban. Canned tomatoes, acidified foods, and fermented foods are allowed but come with additional pH testing, process, and recordkeeping requirements — read the IDPH guide before you start on those.

Prohibited under 410 ILCS 625/4:

If your product is on that list, cottage food law is not your path in Illinois. Jerky makers, cheesecake bakers, kombucha brewers, and anyone canning low-acid vegetables need a licensed commercial or shared-use kitchen and a food establishment permit from the local health department. 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

Illinois is unusually generous on channels and unusually explicit on the boundary. Shipping is permitted inside the state, limited to foods that don't need time or temperature control for safety, and the package needs a tamper-evident seal. On interstate, the statute doesn't leave it to inference: "A cottage food product shall not be shipped out of State." That's a direct Illinois prohibition, not just the federal jurisdictional problem — though the federal point applies too. 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 exemption cannot exempt you from federal law.

The cap, the registration, and the training

Two things make Illinois different from most states, and both cost money and time before you sell anything.

Registration is local, and it varies. Section 4(c) says a local health department "shall register any eligible cottage food operation that meets the requirements of this Section" and issue a certificate with an identifying registration number. Registration is annual and the department "may impose a fee not to exceed $50." That's a ceiling, not a price — what you pay, what forms you file, and how long you wait depend on which of Illinois's local health departments covers you. IDPH says processing can take up to six weeks. Start there, not with your labels, because the registration number has to be printed on every package.

You need a Certified Food Protection Manager. Section 4(b)(6) requires that anyone preparing or packaging cottage food be a Department-approved CFPM: an ANSI-accredited course of at least eight hours with a proctored exam, valid five years, running $100 to $300 per IDPH's guide. Staff who only handle sales, marketing, or administration don't need it. It's a real barrier compared to a food handler card, and the requirement Illinois newcomers most often discover late.

What Illinois doesn't have is a ceiling. The state's cottage food guide puts the question and answer plainly: "Is there a sales cap on my earnings? No. In previous versions of the bill there had been limits, but those no longer apply." You can run this to whatever size the direct-to-consumer channel supports.

When you outgrow cottage food

There's no cap here, so nobody in Illinois ages out on revenue. You leave the program a different way. Any of these ends the exemption:

• A grocery store, coffee shop, or distributor wants to buy for resale.
• You want to ship to a customer in Wisconsin or Indiana.
• You want to make jerky, cheesecake, kombucha, or anything else on the prohibited list.
• You want to say "high protein" on the bag.
• You list on Amazon.

Whichever comes 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 picked. A discrete unit holding 200% to 300% of the RACC needs a dual-column panel.

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 in 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 file nothing at all.

The exemption is void — filed or not — for any product carrying a nutrient content claim, a health claim, or other nutrition information, on the label, in labeling, or in advertising. See FDA's food labeling guide 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. Compare that to $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

Illinois has amended this law twice in five years and its registration mechanics live at the county level, so two things need checking before you print: the state rules, and whatever your specific health department wants.

• Illinois Department of Public Health — Cottage Food
• 2026 Cottage Food Guide (PDF) — developed by IDPH, published by University of Illinois Extension
• 410 ILCS 625/4, full text — source note: P.A. 102-633, eff. 1-1-22; 103-903, eff. 1-1-25
• Your local health department, for registration forms, fee, and turnaround. Chicago registers through CDPH.

Last reviewed August 4, 2026. If you're reading this much later, confirm the disclaimer wording and your county's registration fee before relying on either.