Spice blend label requirements

The hard part of spice blend label requirements isn't the panel. It's the ingredient list, where the word "spices" does a specific and narrow job that most makers assume is broader than it is. Garlic powder is not a spice. Salt is not a spice. Paprika is a spice and also a color, and it gets its own rule.

When may you write "spices" instead of naming each one?

This is the central question for the category, and it's answered by 21 CFR 101.22.

101.22(h)(1) grants the permission: "Spice, natural flavor, and artificial flavor may be declared as 'spice', 'natural flavor', or 'artificial flavor', or any combination thereof, as the case may be."

So yes, you may collapse the spices in your blend into the single word Spices, and you never have to reveal your ratio. That's real protection for a recipe.

Then 101.22(a)(2) narrows what "spice" means, and this is where blends go wrong:

"any aromatic vegetable substance in the whole, broken, or ground form, except for those substances which have been traditionally regarded as foods, such as onions, garlic and celery; whose significant function in food is seasoning rather than nutritional; that is true to name; and from which no portion of any volatile oil or other flavoring principle has been removed."

Read the exception clause. Onion, garlic and celery are excluded by name. They are traditionally regarded as foods, not spices. Garlic powder, granulated garlic, onion powder, dehydrated onion and celery flakes all have to be declared by their own common or usual names. They cannot hide inside "Spices."

The regulation then lists what does count. Allspice, anise, basil, bay leaves, caraway seed, cardamom, celery seed, chervil, cinnamon, cloves, coriander, cumin seed, dill seed, fennel seed, fenugreek, ginger, horseradish, mace, marjoram, mustard flour, nutmeg, oregano, paprika, parsley, black, white and red pepper, rosemary, saffron, sage, savory, star aniseed, tarragon, thyme, turmeric.

Note celery seed is on the list even though celery the vegetable is excluded. The seed is a spice; the stalk is a food.

Four things that can never be called "spices"

Salt. Not an aromatic vegetable substance. Declare it as Salt, and remember it's usually the heaviest ingredient in the jar, so it usually goes first.

Sugar and dextrose. Declare by name. They're also added sugars, which matters if you ever have to build a panel.

Spices that are also colors. 101.22 is explicit: "Paprika, turmeric, and saffron or other spices which are also colors, shall be declared as 'spice and coloring' unless declared by their common or usual name." So you have two compliant options — write Paprika, or write Spice and Coloring. What you may not do is bury paprika inside a plain "Spices."

Monosodium glutamate. 101.22(h)(5): "Any monosodium glutamate used as an ingredient in food shall be declared by its common or usual name 'monosodium glutamate.'" Not "flavor enhancer," not "natural flavor." And under 101.22(h)(7), no protein hydrolysate used for its effect on flavor may be declared simply as "flavor," "natural flavor" or "flavoring" — hydrolyzed soy protein and yeast extract-style ingredients get named.

A worked ingredient list

Take a blend that is, by weight: 40% salt, 20% garlic powder, 15% paprika, 10% onion powder, 8% black pepper, 4% cumin, 2% oregano, 1% silicon dioxide.

Not compliant: Spices, salt, anticaking agent.

Compliant: INGREDIENTS: Salt, Garlic Powder, Paprika, Onion Powder, Spices, Silicon Dioxide (anticaking agent).

The black pepper, cumin and oregano collapse into "Spices" and sit in the position of the heaviest of them. Everything else is named because it isn't a spice, or is a spice that's also a color.

One more layer: compound ingredients. If you buy a pre-made chili powder, that's itself a blend — chili pepper, cumin, oregano, garlic powder, sometimes salt. Under 21 CFR 101.4(b)(2) you either declare its components in your list, or declare it by name with its sub-ingredients in parentheses: Chili Powder (Chili Pepper, Cumin, Garlic Powder, Oregano, Salt). You can't inherit someone else's collective term.

Colors and carriers

Certified colors must be named individually. Under 101.22(k)(1), FD&C colors are declared by the name in the applicable regulation in part 74 or part 82, with "Lake" included for a certified color lake. There's no collective term. Colors exempt from certification may be declared as "Artificial Color," "Color Added," or by name under 101.22(k)(2).

Anti-caking agents and carriers get declared. 21 CFR 101.100(a)(3) exempts incidental additives that are "present in a food at insignificant levels and do not have any technical or functional effect in that food." An anti-caking agent in a seasoning blend is doing exactly the job it was added to do, so the exemption doesn't reach it. Declare it.

Those last two usually arrive inside the salt you bought rather than being something you added. Pull your salt supplier's spec sheet; if the salt carries an anticaking agent, it belongs in your parenthetical: Salt (Salt, Yellow Prussiate of Soda). Flavor carriers — maltodextrin, dextrose, rice concentrate, gum arabic — are not spices and not flavors. They get their own names.

Why your seasoning panel is all zeros

A quarter-teaspoon serving of a dry blend weighs on the order of half a gram to a gram and a half. At that mass, nearly every nutrient rounds to zero.

The first question isn't how to format that panel. It's whether you owe one at all.

21 CFR 101.9(j)(4) exempts foods that contain insignificant amounts of all of the nutrients required to be declared, provided the food bears no nutrition claims or other nutrition information in any context on the label, in labeling, or in advertising. "Insignificant" means an amount that allows a declaration of zero, except for total carbohydrate, dietary fiber and protein, where it means an amount that allows a declaration of "less than 1 gram." FDA's own examples of exempt foods include coffee beans, tea leaves, condiment-type dehydrated vegetables, flavor extracts and food colors.

A salt-free herb blend at a quarter-teaspoon serving usually clears that test outright. No panel required. Not a small business exemption, not a state exemption — the food itself is out of scope.

If you don't clear it, the next stop is the simplified format at 21 CFR 101.9(f). It's available when the food contains insignificant amounts of most required nutrients. The simplified format must still show total calories, total fat, total carbohydrate, protein and sodium, plus any other required nutrient present in more than insignificant amounts. And under 101.9(f)(4), when you use it, the statement "Not a significant source of ___" goes at the bottom of the nutrition label, with the blank filled in with the nutrients you left out.

Rounding rules that produce the zeros, from 101.9(c):

A one-gram serving of dried oregano has less than 5 calories, less than half a gram of fat, and single-digit milligrams of sodium. Every line goes to zero. That's not a broken label. That's the correct label, and in most cases it's a label you don't have to print.

Making any claim closes both doors. 101.9(j)(4) is conditioned on no nutrition claims or other nutrition information anywhere, including advertising. Write "low sodium," "keto," "zero calorie" or "packed with antioxidants" and you've bought yourself a full panel. See what counts as a nutrient content claim.

Sodium is the exception that isn't zero

The moment salt goes in the jar, the zeros stop.

Salt is about 39% sodium by weight. A quarter-teaspoon of fine salt weighs roughly 1.5 g, which is about 590 mg of sodium — 26% of the 2,300 mg Daily Value in a single quarter-teaspoon. A blend that's half salt by weight still puts roughly 295 mg, or 13% DV, into that same quarter-teaspoon.

So a seasoned salt or a rub gets a panel with fourteen zeros and one number that matters. That number is the reason your product isn't exempt under 101.9(j)(4).

The "low sodium" claim is much harder than it looks

21 CFR 101.61 sets the thresholds, and it has a special rule for small-serving foods that catches every spice blend.

Because a spice blend's reference amount is a quarter-teaspoon — well under the "30 g or less or 2 tablespoons or less" line — you fall into 101.61(b)(4)(i)(B): the food must contain 140 mg or less sodium per reference amount customarily consumed AND per 50 g.

That second criterion is the killer. Passing "per reference amount" is easy; a quarter-teaspoon of almost anything is small. Passing per 50 g means the blend itself can be no more than roughly 0.7% salt by weight. In practice, "low sodium" on a seasoning means salt-free.

"No salt added," "unsalted" and "without added salt" work differently under 101.61(c). They require that no salt was added during processing and that the food it resembles is normally processed with salt. And unless the food is sodium free, the label has to carry a statement adjacent to the nutrition label that it is "not a sodium free food" or "not for control of sodium in the diet." So a salt-free rub can honestly say "no salt added," but it owes that disclosure alongside it.

Serving size for a seasoning

From Table 2 of 21 CFR 101.12:

That third row is the one people miss. A taco seasoning packet, a chili mix, a gravy or coating mix is not a quarter-teaspoon product. Its reference amount is the amount of dry mix needed to produce one reference amount of the finished dish. Work backwards from the dish's own RACC, then express the answer in teaspoons or tablespoons per the label statement column. Two products that look identical on a shelf — a "chili seasoning" packet and a "chili powder" jar — can sit in different rows.

Weigh a level quarter-teaspoon of your own blend rather than borrowing a gram figure. A quarter-teaspoon of fine salt and a quarter-teaspoon of dried oregano leaf are not remotely the same weight, and every number on your panel scales off that measurement. Our serving size guide has the full method.

Allergens in a spice blend

The nine major allergens are milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, soybeans and sesame — sesame added by the FASTER Act effective January 1, 2023.

Seasonings carry more of them than people expect:

• Sesame in za'atar, dukkah, everything-bagel blends, gomasio, and any tahini-derived component. Sesame is the newest allergen and the one most often missed on legacy labels.
• Wheat as a carrier or thickener in gravy, coating and sauce mixes.
• Milk in ranch, cheese and creamy seasonings — buttermilk powder, whey, cheese powder.
• Soy in hydrolyzed soy protein and some flavor carriers.
• Tree nuts in pesto-style and dukkah blends. Species must be named: "Contains: Pistachios," not "Contains: Tree Nuts."

Two things worth being straight about. Mustard is not a major allergen in the United States. It is in Canada and the EU. Mustard flour is on FDA's spice list and can be declared inside "Spices" — but if you export, or your customer base expects it, name it. And "may contain" advisories are voluntary. FDA does not require them and they never substitute for a required declaration. Our contains statement guide covers both legal declaration methods.

Net weight, not volume, on a light bulky product

21 CFR 101.7(b) decides this: "The statement shall be in terms of fluid measure if the food is liquid, or in terms of weight if the food is solid, semisolid, or viscous." A dry blend is solid. It declares NET WT, in the bottom 30% of the principal display panel under 101.7(f).

That single rule causes more trouble in this category than any other, because spice packaging is sold to you in fluid ounces. A jar described by its supplier as "4 oz" is a 4 fluid ounce cavity. Fill it with fine salt and it holds several ounces by weight. Fill it with whole dried oregano leaf and it holds a small fraction of that. Neither one weighs 4 oz just because the jar is called a 4 oz jar.

Three practical rules:

1. Fill by weight, weigh finished jars, declare that weight. Never transcribe the jar's nominal size.
2. Expect settling. Bulky leaf products compact in transit. 101.7(q) recognizes "reasonable variations caused by loss or gain of moisture during the course of good distribution practice or by unavoidable deviations in good manufacturing practice" — but that covers variation, not a jar chosen to look bigger than its contents. Nonfunctional slack-fill is its own misbranding problem under 21 CFR 100.100.
3. Print both units. FDA's 101.7(p) treats metric as permitted rather than required, but the Uniform Packaging and Labeling Regulation in NIST Handbook 130, adopted into law in 45 states, requires both. NET WT 1.8 OZ (51 g).

Small jars also get relief under 21 CFR 101.9(j)(13): an exemption tied to how much total surface area a package has available to bear labeling, plus compressed tabular and linear display formats at 101.9(j)(13)(ii)(A). Read the paragraph before you shrink a panel to fit — the relief is conditioned on making no nutrition claims.

Cottage food eligibility, state by state

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")
2. You make a health claim
3. You outgrow your state's cottage food cap and move to a commercial kitchen
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

Dry seasoning blends are the single most widely permitted cottage food product in the country. Every state we cover allows them.

Two cautions. Anything wet is a different animal — a wet rub, a paste, a marinade or an oil-based blend leaves the dry-goods category and can leave the cottage food exemption entirely. And a state exemption from inspection is never an exemption from 21 CFR Part 101. Verify with your state agency before a print run.

What it costs if you do need a panel

Sending a seasoning blend to a lab is the clearest case of overpaying in this industry: four figures of wet chemistry to produce a column of zeros and one sodium figure you could calculate from your salt weight. See how much a nutrition label costs and lab versus software.

If you do need one — because you're on Amazon, because a retailer asked, or because you made a claim — Nutrillius builds the panel from your recipe, applies the simplified format when it qualifies, and rounds sodium correctly. $39 one time, PNG/PDF/SVG, 90 days of edits. Build a seasoning label.