Vermont cottage food label requirements

That cap is new. Act 42 of 2025 (H.401) took effect July 1, 2025 and replaced the old home-bakery exemption of $125 a week with a "cottage food operator" exemption covering any shelf-stable food up to $30,000 in gross annual receipts. If you're working from a guide that still talks about $6,500 a year or bakery products only, it predates the rewrite.

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 Vermont actually requires

Section 6.2.1 of the Manufactured Food Rule says a license-exempt food manufacturing establishment "shall label products for sale with the following information":

1. The name and address of the operation. The Health Department's guidance says to use the physical address of your home kitchen, not a post office box, so the product can be traced in a recall.
2. The name of the food product.
3. The ingredient list, in descending order of predominance by weight. Sub-ingredients count. If your chocolate chips contain soy lecithin, that has to show up.
4. Net weight or net volume.
5. Allergen declaration "as specified by federal labeling requirements." 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."
6. Nutrition labeling, if you make a nutrient content claim, a health claim, or provide other nutritional information. More on this below, because Vermont wrote the trigger into its own rule.
7. The Vermont disclaimer, word for word.

The exact disclaimer wording

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

Section 6.2.1.1.7 requires it "printed in at least 10-point type in a color that provides a clear contrast to the background label." Sentence case, as written, ending in a period.

Don't paraphrase it, don't shorten it to "made in a home kitchen," and don't set it in 6-point grey on kraft paper. Inspectors read this string literally, and the Health Department's own label example prints it as the last line on the package.

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.

Vermont's rule copies trigger one into state law. Section 6.2.1.1.6 requires "nutritional labeling as specified by federal labeling requirements" the moment "any nutrient content claim, health claim, or other nutritional information is provided." The Health Department's FAQ says the same thing in plain English: almost all exempt producers are exempt from nutrition labeling, until they say "sugar-free" or "low fat." With a $30,000 cap and a hard no on selling to restaurants and stores, triggers one and three are what actually bite here.

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 Vermont

Vermont uses a definition model rather than a closed list. Under 18 V.S.A. § 4301(a)(6), a cottage food product is any food "that does not require refrigeration or time or temperature control for safety." The statute then gives examples, and the Commissioner can add more by rule or policy. If your product is shelf-stable and not on the list, it still qualifies; the Health Department says you don't need its approval, though you can request a review for certainty.

Allowed (the statutory examples): nonpotentially hazardous baked goods; candy; jams and jellies; dry herbs; trail mix; granola; cereal; mixed nuts; flavored vinegar; popcorn; coffee beans; dry tea; and home-canned pickles, vegetables, or fruits with a pH of 4.6 or lower or a water activity of 0.85 or less, made from a recipe approved by the National Center for Home Food Preservation or reviewed by a food processing authority.

Prohibited under the exemption:

If your product is on that prohibited list, the cottage food exemption is not your path. You'll need a Home Bakery, Home Caterer, or food manufacturing license from the Health Department, or 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 clearest line is wholesale. The Health Department's guidance says "Food service establishments, like restaurants, may only purchase food products from licensed food manufacturers," and its FAQ answers "No" to selling exempt products to a local restaurant. If a shop or a café wants to carry you, you need a license, not an exemption.

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

Two things people miss. First, the exemption is not automatic. Under 18 V.S.A. § 4358(c) you must file a licensing exemption every year and attest that you completed the training; the Department sends no certificate back, so keep your own record. Second, the $30,000 is specific to cottage foods. Act 42 also exempts "food processors" with gross annual sales of $10,000 or less, and the Department confirms you can stack them: $30,000 of cottage foods plus $10,000 of other processed foods, both exempt.

Cross $30,000 and you need a license. A Home Bakery License with gross receipts over $30,000 costs $100 a year under § 4353; a nonbakery food manufacturing license runs $175 up to $50,000 in receipts and $275 above that. You apply at least 30 days before you plan to open and pass an opening inspection.

When you outgrow cottage food

Crossing $30,000 is not the only way out of cottage food. Any of these ends the exemption:

• You hit the sales cap.
• A restaurant or a store wants to carry you.
• You want to rent a commercial kitchen.
• You want to make cheesecake, jerky, or anything else that needs refrigeration.
• 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 Vermont has moved twice in two years: Act 42 (2025) created the exemption on July 1, 2025, and the Health Department's permanent Manufactured Food Rule, which carries the label wording, took effect January 15, 2026. Before you print labels, check the current rules with the agency directly:

• Vermont Department of Health — Home-Based Food Licenses and License Exemptions
• Vermont Department of Health — Food Manufacturing Licensing Exemptions (PDF, November 2025)
• Manufactured Food Rule (PDF), Section 6.2.1
• 18 V.S.A. § 4358: Exemptions
• Act 42 of 2025 (H.401), as enacted

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.