Oregon cottage food label requirements

Oregon has two home-kitchen paths and people mix them up. The Cottage Food Exemption is what this page covers: no license, no application, a short approved-food list, and the cap. The Domestic Kitchen license (bakery or processor) is the licensed, inspected alternative with no cap, a wider menu, and an annual fee. Senate Bill 643 (2023) turned the old "home baking bill" into the current exemption, and the Oregon Department of Agriculture (ODA) rules implementing it took effect April 18, 2024.

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 Oregon actually requires

Under ORS 616.723(6) and OAR 603-025-0325, every prepackaged cottage food product you sell in Oregon needs all of the following on the label:

1. The Oregon disclaimer, word for word, on the principal display panel. Wording below.
2. The name of the food.
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. Oregon's rule points at the federal Food Allergen Labeling and Consumer Protection Act. Federal law covers 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 business name of your cottage food establishment.
6. Your address, in one of three forms: the full street address with city, state, and ZIP; the city, state, and ZIP alone if your name and address are in a city directory; or an ODA-issued Unique Identification Number. A P.O. box is not an option. The UIN costs $25 a year, expires every June 30, and is the way to keep your home address off a cookie bag.
7. Your telephone number. ODA's FAQ confirms it is mandatory, citing ORS 616.723(6)(b)(A).
8. Net weight or net volume, in both U.S. and metric units. Oregon is one of the few cottage states that writes the metric requirement in.
9. A pet statement, if pets live in your home. The label must say pets were present in the residence and name the species by its common name: "cat," "dog," "rabbit."

A tenth element is conditional and is the whole reason this page exists: if the label makes "any nutrient content claim, health claim, or other nutritional statement," OAR 603-025-0325(2)(h) requires nutrition information "as described in 21 CFR Part 101." Oregon wrote the trigger into its own rule.

The exact disclaimer wording

This product is homemade, is not prepared in an inspected food establishment, and must be stored and displayed separately if merchandised by a retailer.

OAR 603-025-0325(1) puts it on the principal display panel. Subsection (3) sets the type size for the whole label: at least 1/16 inch, measured by the height of a lowercase "o," prominently displayed and not obscured by logos or artwork.

Don't paraphrase it, don't drop the retailer clause because you only sell at markets, and don't bury it on the back. For unpackaged single items at a market stand, ODA accepts a placard reading "This product is homemade and is not prepared in an inspected food establishment," with the rest of the label information available on request.

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.

Oregon is unusual on trigger four. The exemption lets you sell packaged cottage food to retailers, so a grocery shelf does not end the exemption by itself. What the retailer asks for is another matter: a store shelving your jar next to commercially made products will often want a panel as a condition of carrying you. And trigger one is written straight into OAR 603-025-0325(2)(h), so "low sugar" on an Oregon jam label requires the nutrition information behind it even while you stay in cottage food.

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 Oregon

Oregon uses an approved-list model. If it isn't in OAR 603-025-0320(1)(c), you can't make it under the exemption.

Allowed, under OAR 603-025-0320(1)(c):

Prohibited:

Anything time/temperature controlled for safety, anything containing marijuana or marijuana items, and all meat. ODA's FAQ names the common casualties: cream pies, cheesecakes, pastries with cream, custard, meringue, or cream cheese fillings, focaccia with vegetables or cheese, caramel apples and chocolate-covered strawberries, pot pies, pickles (a cucumber's natural pH is above 4.60), pepper jelly (same problem), bottled brewed tea, and pet treats. Some of those are legal under Oregon's separate Farm Direct rules, but not under cottage food.

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, or an ODA Domestic Kitchen 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

ORS 616.723(4) lets you sell "directly to the end user in any manner, including from the home, online, through the mail and at events." Retail is allowed under OAR 603-025-0320(4) if the product is packaged and labeled, the retailer agrees to store and display it separately with signage saying it is homemade and not prepared in an inspected food establishment, and you keep a record of that agreement. Institutions are out, and another processor may not use your cottage food as an ingredient.

On state lines, ODA says it has no "jurisdictional authority in other states to make that determination" and tells you to ask the destination state. The statute itself draws no in-state boundary, unlike Texas or California. ODA also warns that its Unique Identification Number does not satisfy federal address requirements if you sell into interstate commerce.

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 base cap in ORS 616.723(2)(d) is $50,000. ODA's inflation rule for 2026 (DOA 95-2026, effective March 13, 2026) moved it from $51,200 to $52,700 after a 2.9 percent CPI rise. It will move again in 2027, so confirm the current-year number with ODA before you cut it close. Your Farm Direct sales, if you have any, count against a separate $50,000 limit.

If you want to stay in your home kitchen past the cap, ODA's Domestic Kitchen license is the next step. For the 2026-27 fiscal year a Domestic Kitchen Bakery license starts at $179 a year for sales up to $50,000 and scales with sales, and a Domestic Kitchen Processor license is a flat $223. Both are inspected.

Local rules still apply. The exemption only relieves you of ODA licensing and routine inspection; zoning and local business rules are yours to check.

When you outgrow cottage food

Crossing $52,700 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 ship out of state.
• You want to make something on the prohibited list.
• 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 Oregon has moved recently: SB 643 in 2023, new ODA rules in April 2024, and a cap adjustment every March since. Before you print labels, check the current rules with the agency directly:

• Oregon Department of Agriculture — Oregon's Cottage Food Exemption (PDF) and the ODA Cottage Food Exemption FAQ (PDF)
• ORS 616.723: Oregon Revised Statutes Chapter 616
• ODA 2026 cottage food inflation rule, DOA 95-2026 (PDF)
• ODA Food Safety License Fee Schedule 2026-2027 (PDF)

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