Minnesota cottage food label requirements

You register with the Minnesota Department of Agriculture (MDA) before your first sale, in one of two tiers, after a food safety course. The law was rewritten in 2025, but almost none of that takes effect until August 1, 2027. Until then the rules below apply.

The label Minnesota actually requires

Minn. Stat. § 28A.152, subd. 1(a)(1) requires that food be "labeled to accurately reflect" all of the following:

1. Your name.
2. Your MDA registration number or your address.
3. The date the food was prepared.
4. The ingredients and any possible allergens. Ingredients in descending order by weight. Sub-ingredients count. If your chocolate chips contain soy lecithin, that has to show up. MDA names the nine major allergens: milk, eggs, wheat, soy, peanuts, tree nuts, fish, shellfish, and sesame. Sesame joined the federal 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 — "walnuts," not "tree nuts."
5. The Minnesota statement, word for word.

Net weight is not on the list.

The exact disclaimer wording

These products are homemade and not subject to state inspection.

Exactly as written in Minn. Stat. § 28A.152, subd. 1(a)(1)(i), ending in a period. No type size is specified.

The same sentence also goes on "a clearly legible sign or placard" at the point of sale (subd. 1(a)(1)(ii)) and "on the website that offers the exempt foods for purchase" (subd. 2(d)).

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.

Trigger four is the near-term risk here. MDA says wholesaling to a business "requires a food license," and most makers meet a retail buyer before they meet $78,000.

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 Minnesota

Minnesota uses an exclusion model built on a safety test: subd. 1(a)(1) covers any "food that is not potentially hazardous," and subd. 1(a)(2) adds qualifying home-canned pickles, vegetables, and fruits.

Allowed:

Prohibited, per MDA guidance:

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 an MDA food license, 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

Current subd. 2(b) says the preparer "must be the person who delivers the food product to the ultimate consumer"; subd. 2(d) allows internet sales on the same condition. MDA: "Mail and third-party shipping are not allowed" for human food. Home-canned products "may not be sold outside of Minnesota" (subd. 2(c)).

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 statute sets the fee waiver at "$5,000 or less" adjusted for inflation (subd. 4); MDA's current figure is $7,665. The cap is gross receipts, not profit (subd. 3). Subd. 6 leaves local business licensing, sanitation, public health, and zoning ordinances in force.

What changes on August 1, 2027

Laws 2025, chapter 34, article 5 (HF 2446) rewrote subdivisions 1 to 5 and added subdivision 8, effective August 1, 2027:

• One registration tier with a flat $30 annual fee.
• Delivery "by the person who prepared the food product, by mail, or by commercial delivery."
• Every registrant takes the approved course every three years.
• The $78,000 cap is adjusted for CPI every two years from a July 2025 base.
• Small LLCs qualify; § 28A.04 food handler licensees do not.
• The label statement does not change.

When you outgrow cottage food

Crossing $78,000 is not the only way out of cottage food. Any of these ends the exemption:

• You hit the sales cap.
• You want to sell wholesale or into grocery.
• You want to make jerky, cheese, or anything that fails the water-activity test.
• You want to say "high protein" on the bag.

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 Minnesota has moved twice recently: in 2021 (the current cap and tiers) and 2025 (effective 2027). Check the current rules with the agency directly:

• Minnesota Department of Agriculture — Cottage Food Law Guidance
• Minn. Stat. § 28A.152: Cottage foods exemption, Revisor of Statutes

This page was last reviewed October 30, 2026. If you're reading it much later than that, verify the Tier 1 threshold and the delivery rule before you rely on either.