Iowa cottage food label requirements

House File 2431, effective July 1, 2022, split Iowa's home food law in two: unlicensed "cottage food" and the licensed "home food processing establishment," which has its own $50,000 ceiling. The label rules below are for cottage food.

The label Iowa actually requires

Iowa Code § 137F.20(2) says cottage food "shall be affixed or labeled with all of the following information":

1. Your name, plus an address, phone number, or email address. The statute says "the name and address, phone number, or electronic mail address of the person preparing the food," so a name and an email satisfies it.
2. The common name of the food. "Sourdough bread," not "Hawkeye Loaf."
3. The ingredient list, in descending order by weight. Sub-ingredients count. If your chocolate chips contain soy lecithin, that has to show up.
4. Allergen declaration. The statute requires a statement naming "each major allergen contained in the food by the common name of the allergen." The Department of Inspections, Appeals, and Licensing (DIAL) lists the federal nine: milk, eggs, fish, crustacean 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 — "almonds," not "tree nuts."
5. The Iowa disclaimer, word for word.

Net weight is not on Iowa's list. Home-canned pickles, vegetables, or fruits add a sixth element under § 137F.20(2)(e): the date the food was processed and canned.

The exact disclaimer wording

This product was produced at a residential property that is exempt from state licensing and inspection.

Sentence case, ending in a period, exactly as in Iowa Code § 137F.20(2)(d). No type size is specified.

Don't paraphrase it, and don't confuse it with the licensed-kitchen version under § 137D.2(7)(f): "This product was produced at a home food processing establishment."

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.

Iowa has no cap, so trigger four is the live one. Section 137F.20 exempts you only "if the food is sold and delivered by the producer directly to the consumer." A grocery buyer saying yes is the usual way an Iowa maker ends up needing a panel.

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 Iowa

Iowa uses an exclusion model. Under § 137F.1(3), cottage food is any food "produced at a private residence other than time/temperature control for safety food," with two categories carved out. If it is shelf-stable and not excluded, it's allowed.

Allowed:

Prohibited:

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, 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

The exemption holds only when food is "sold and delivered by the producer directly to the consumer." The statute draws no geographic line, but § 137F.20(3) says something few cottage food laws do: "Compliance with the cottage food exemption provided in this section does not represent compliance with federal law."

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 home food processing establishment is Iowa's upgrade path: resale and some refrigerated foods, in exchange for a license, inspections, a ceiling, and its own label statement.

When you outgrow cottage food

Iowa has no cap, so the exits are product and channel:

• A grocery or coffee shop wants to stock you.
• You want to make cheesecake or anything refrigerated.
• You want to ship to a customer in Illinois.
• You want to say "high protein" on the bag.
• You list on Amazon.

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 Iowa rewrote its law in 2022; a 2026 bill to allow grocery-store sales (HF 2767) passed the House 89–0 on April 27, 2026 and stopped there. Check the current rules with the agency directly:

• Iowa DIAL — Cottage Food Law
• Iowa Code § 137F.20: Cottage food — requirements (PDF)
• Iowa Code chapter 137D: Home food processing establishments (PDF)

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