General Labeling Requirements

All product labels must have the following four required statements:

  1. an identity statement
  2. a net weight statement
  3. a list of ingredients
  4. company name and address

General label requirements:

  • The minimum print size for each of the four required statements is 1/16 inch.
  • The product identity and net weight statements must appear on the portion of the label displayed to the consumer.
  • The ingredient listing and company name statements must be easy to see on the package label.
  • If your company is producing more than 100,000 units annually and has more than 100 employees, nutrition facts panel may be required. See below for more details.
  • If your product contains any of the following, you are required to clearly identify these major allergens: milk, eggs, fish, crustacean shellfish, tree nuts, peanuts, wheat, or soybeans. See below for more details.

What is an identity statement?

  • The common name of the food, or an appropriate descriptive term.
  • A fanciful name commonly used by the public is acceptable when the nature of the food is obvious.
  • Brand names, trademarks, or product identities that are misleading will not be allowed (i.e. Mountain Water, when the water is from a well on the plains).

What is Net Weight?

  • The net contents are listed in either ounces, pounds, fluid ounces, pints and/or quarts depending on the consistency of the product and common practice.
  • The net weight statement shall have the words Net Weight, or Net Wt. for food products sold by weight. The terms Fl. oz., or Net_ fl. oz. or Net Contents_ fl. oz. shall be used for products sold by fluid measure.
  • The net weight statement must be parallel to the base of the package and shall be in the lower 30% of the label.
  • Labeling requirements for net weight are very specific based on your product and packaging. Detailed information from the Colorado Department of Public Health and the Environment.

How do you list ingredients?

  • Ingredients are listed in decreasing order of predominance from most to least. The ingredient with the greatest quantity is listed first and the least is listed last.
  • All of the food ingredients must be listed by their common or usual name.
  • If an ingredient you use contains other two or more other ingredients, these must be listed as well.
    • Example: you use soy sauce in your product. List the contents of an ingredient in parentheses behind the ingredient: soy sauce (water, wheat, soy beans, salt, spices, etc.)
  • Shortening or oils must be identified by the common name such as soybean oil, corn oil, lard, etc.
  • Spices except for salt, garlic, celery and onions can generally be described as spices, but other spices may need to be identified.

How do I list my company name and address?

  • The name and complete address (including street address, city, state, and zip code) of the manufacturer, packer, or distributor of the product must be listed on the label. Post office boxes cannot be substituted for physical addresses.
  • The street address can be omitted if the business name, as it appears on the label, is listed in either the telephone book or can be obtained from directory assistance for the city listed on the label.
    • If the firm listed on the label does not manufacture the food, then the relation between the firm and the food must be declared with a term such as “Distributed by” or “Packed by” or “Manufactured for”.

Nutrition Labeling and Education Act (NLEA) stipulations:

  • A nutrition facts panel may be required if nutritional claims are made on the label or if the company is producing more than 100,000 units annually and has more than 100 employees.
  • For more information refer to the FPLA or “A Food Labeling Guide” and/or feel free to contact the Consumer Protection Division of the Colorado Department of Public Health and Environment at (303) 692-3620.
  • For more information on product testing contact CDPHE at (303) 692-3090 or contact the following laboratories to get your product tested for nutritional content:
    Industrial Laboratories, (303) 287-9691
    Warren Analytical Laboratory, (970) 351-6648
    CSU Food Processing Support Laboratory, (970) 491-3874

Labeling foods with allergenic ingredients:

What is an allergenic ingredient?

  1. milk
  2. eggs
  3. fish
  4. crustacean shellfish
  5. tree nuts
  6. peanuts
  7. wheat
  8. soybeans

Required details to be listed on ingredients:

  • Type of tree nut (e.g., almonds, pecans, walnuts)
  • Type of fish (e.g., bass, flounder, cod)
  • Type of Crustacean shellfish (e.g., crab, lobster, shrimp)

What are the labeling requirements?

Food manufacturers are required to label foods in one of two ways, if allergenic foods are present:

1. In the list of ingredients, put the name of the food source of the major food allergen in parenthesis after the common or usual name of the ingredient when that name does not already appear in the ingredient statement. Example (allergens are listed in bold for demonstration only; this is not a labeling requirement)

Ingredients: Enriched flour (wheat flour, malted barley, niacin, reduced iron, thiamin mononitrate, riboflavin, folic acid), sugar, partially hydrogenated soybean oil, and/or cottonseed oil, high fructose corn syrup, whey (milk), eggs, vanilla, natural and artificial flavoring, salt, leavening (sodiumacid pyrophosphate)

2. Immediately after or adjacent to the list of ingredients, put the word “Contains” followed by the name of the food for each of the major food allergens present in the food’s ingredients.
Example: Contains Wheat, Milk, Egg, and Soy

Making therapeutic claims on your label: Making “therapeutic claims” that promote products for the cure, mitigation, treatment, or prevention of disease is equivalent to making new drug claims. This requires FDA approval based on scientific data.

Some examples of claims that would require FDA approval include:

  • Ginger is used in food and drinks as a preventive medicine against colds and flu
  • The powerful antioxidants found in tea are believed to help prevent cancer and lower cholesterol
  • Recent research suggests consuming 5-8 cups of tea each day can reduce cholesterol and plaque of the arteries

Country of Origin Labeling:

Country of Origin Labeling (COOL) is a labeling law that requires retailers, such as full-line grocery stores, supermarkets, and club warehouse stores, notify their customers with information regarding the source of certain foods.  Food products, (covered commodities) contained in the law include muscle cut and ground meats: beef, veal, pork, lamb, goat, and chicken; wild and farm-raised fish and shellfish; fresh and frozen fruits and vegetables; peanuts, pecans, and macadamia nuts; and ginseng.

For purposes of COOL, the definition of “retailer” generally includes most grocery stores and supermarkets. Retail stores such as fish markets and butcher shops as well as other stores that do not invoice the threshold amount of fresh produce (fruits and vegetables) are exempt from this regulation. Restaurants and other food service establishments (cafeterias, lunchrooms) are also exempt.  The term “food service establishment” means a restaurant, cafeteria, lunch room, food stand, saloon, tavern, bar, lounge, or other similar facility operated as an enterprise engaged in the business of selling food to the public. Similar food service facilities include salad bars, delicatessens, and other food enterprises located within retail establishments that provide ready-to-eat foods that are consumed either on or outside of the retailer’s premises. Under this definition, a farmers’ market is a food service establishment and therefore not subject to COOL labeling.

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