how to make a nutrition facts label (2026 FDA guide)

A Nutrition Facts label looks simple — a black-and-white box with some numbers. Under the hood it’s one of the most tightly specified pieces of design in American commerce: 21 CFR 101.9 dictates the exact nutrients, the exact order, the exact rounding increments, the type sizes, even the thickness of the horizontal rules. The good news: once you understand the eight steps below, the process is completely mechanical — which is also why software can do most of it for you.

1. Determine the serving size (RACC)

You don’t get to pick a flattering serving size. The FDA publishes Reference Amounts Customarily Consumed (RACCs) — standardized amounts for every food category (e.g. cookies ≈ 30g, beverages ≈ 240mL, hot sauce ≈ 5mL... the exact value depends on your category). Your declared serving size must be based on the RACC for your product category, expressed as a household measure plus the gram weight, like “2/3 cup (55g)” or “1 bar (40g)”.

• Find your category in the FDA’s RACC tables (21 CFR 101.12).
• Convert the RACC into a sensible household unit for your product (pieces, cups, tbsp).
• Servings per container= net contents ÷ serving size, with its own rounding conventions (e.g. “about 2.5”). Packages containing 200%–300% of the RACC may also need dual-column “per serving / per container” labeling.

2. Gather nutrient data for every ingredient

For each ingredient you need nutrient values, normally per 100 grams: calories, total fat, saturated fat, trans fat, cholesterol, sodium, total carbohydrate, dietary fiber, total sugars, added sugars, protein, vitamin D, calcium, iron and potassium. Sources, in order of convenience:

• USDA FoodData Central — the government reference database; free and FDA-accepted for label calculation. (This is what the Nutrillius ingredient library is built on — 7,700+ ingredients.)
• Supplier spec sheets— for commercial ingredients (chocolate chips, flavor bases), the manufacturer’s spec is usually more accurate than a generic database entry.
• Lab analysis — for the edge cases covered in step 10.

3. Calculate per-serving amounts

The math itself is straightforward:

1. Convert every recipe quantity to grams (1 cup of flour ≈ 125g, 1 tbsp of honey ≈ 21g — cup weights differ per ingredient, which is where most DIY spreadsheets go wrong).
2. For each nutrient: sum (grams of ingredient ÷ 100) × per-100g value across all ingredients.
3. Divide each total by the number of servings.

4. Apply the FDA rounding rules

You cannot print raw calculated numbers. 21 CFR 101.9(c) assigns each nutrient its own rounding increments — calories under 5 become 0, calories from 5–50 round to the nearest 5, above 50 to the nearest 10; cholesterol between 2 and 5mg is declared as “less than 5mg”; carbohydrate under 0.5g becomes 0, and so on. We published the complete tables in our FDA rounding rules guide — it’s the same logic the Nutrillius engine runs.

5. Compute % Daily Values

Percent Daily Value is calculated by dividing the per-serving amount by the FDA’s Daily Value for that nutrient (e.g. 78g total fat, 2,300mg sodium, 50g added sugars, 28g fiber) and expressing it to the nearest whole percent. Two subtleties people miss:

• The FDA permits calculating %DV from the unrounded amount, which occasionally produces a %DV that looks inconsistent with the rounded gram value — that’s expected and correct.
• Trans fat and total sugars get no %DV — no Daily Value has been established for them.

6. Choose the label format

There are also special cases — dual-column (as packaged / as prepared), simplified format when 8+ nutrients are zero, and aggregate formats for variety packs. Nutrillius generates vertical, tabular and linear formats with a live preview of each.

7. Write the ingredient statement

Separate from the panel, 21 CFR 101.4 requires every ingredient listed in descending order by weight, by its common or usual name, with multi-component ingredients broken out in parentheses — e.g. “chocolate chips (sugar, chocolate liquor, cocoa butter, soy lecithin)”. Water counts as an ingredient (at its added weight). Get the order from your gram weights in step 3 — never guess it.

8. Declare major allergens

Federal law (FALCPA, plus the FASTER Act which added sesame in 2023) recognizes nine major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame. You must identify them either in the ingredient list by their common names or in a separate “Contains:”statement immediately after it — “Contains: Milk, Wheat, Soy.” Species matter for fish, crustacean shellfish and tree nuts (declare “almonds”, not just “tree nuts”).

9. Print specs & export

• Type sizes are regulated: “Nutrition Facts” must be the largest text on the panel; core information generally can’t drop below 8-point (6-point on small packages), with specified hairline and bar thicknesses.
• Export vector when you can — an SVG or vector PDF stays razor sharp at any print size; a low-resolution PNG on a 5,000-unit print run is an expensive mistake.
• Print black on white (or another single dark color on a light contrasting background) — decorative color inside the panel is not allowed.

10. Database calculation vs lab analysis

The FDA accepts either method. Database calculation (what this guide — and Nutrillius — uses) is accurate and dramatically cheaper for most recipes made from known ingredients. Send a sample to a lab when:

• Processing changes composition in ways you can’t model — deep frying, fermentation, smoking, extrusion;
• You’re making a nutrient content claim (“high protein”, “low sodium”) you may need to defend with data;
• Your supplier data is incomplete or untrustworthy.

A full lab panel typically runs hundreds of dollars per revision, which is why most small brands start with database calculation — see the full breakdown in how much a nutrition label costs.

The 7 mistakes that get labels rejected

After the process itself, here’s what actually goes wrong. These are the errors buyers, co-packers and regulators catch most often:

1. Volume-to-gram guessing.Using one universal “cup = 240g” conversion. A cup of flour is ~125g, a cup of honey ~340g — get this wrong and every number downstream is wrong.
2. Batch weight instead of baked weight. Ignoring moisture loss (step 3) understates every nutrient per serving.
3. Self-serve serving sizes.Declaring a 15g “serving” of cookies to flatter the calories — the RACC says otherwise, and buyers check.
4. Printing unrounded numbers.“187 calories” flags the label as amateur instantly — see the rounding tables.
5. Ingredient list in recipe order. It must be descending by weight — recipe order is a different order.
6. Missing hidden allergens.Soy lecithin in chocolate, wheat in soy sauce, milk in “natural flavor” butter powder. Trace every compound ingredient.
7. Low-res raster art at print. The panel must stay legible at regulated type sizes — send your printer vector SVG or PDF, never a screenshot.