Guidance for Industry: A Food Labeling Guide (3. General Food Labeling Requirements)
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- Where should label statements be placed on containers and packages?
- What are the PDP and the alternate PDP?
- What label statements must appear on the PDP?
- Which label panel is the information panel?
- What is information panel labeling?
- What type size, prominence and conspicuousness is required?
- What is the prohibition against intervening material?
- What name and address must be listed on the label?
1. Where should label statements be placed on containers and packages?
Answer: There are two ways to label packages and containers:
- Place all required label statements on the front label panel (the principal display panel or PDP), or,
- Place certain specified label statements on the PDP and other labeling on the information panel (the label panel immediately to the right of the PDP, as seen by the consumer facing the product).
Answer: The PDP, is that portion of the package label that is most likely to be seen by the consumer at the time of purchase. Many containers are designed with two or more different surfaces that are suitable for display as the PDP. These are alternate PDPs. 21 CFR 101.1
Answer: Place the statement of identity, or name of the food, and the net quantity statement, or amount of product, on the PDP and on the alternate PDP. The required type size and prominence are discussed in sections 4 and 5 of this guidance. 21 CFR 101.3(a) and 21 CFR 101.105(a).
Answer: The information panel is the label panel immediately to the right of the PDP, as displayed to the consumer. If this panel is not usable, due to package design and construction, (e.g., folded flaps), then the information panel is the next label panel immediately to the right. 21 CFR 101.2(a)
Answer: The phrase "information panel labeling" refers to the label statements that are generally required to be placed together, without any intervening material, on the information panel, if such labeling does not appear on the PDP. These label statements include the name and address of the manufacturer, packer or distributor, the ingredient list, nutrition labeling and any required allergy labeling. 21 CFR 101.2(b) and (d), Section 403(w) of the FD&C Act
Answer: For information panel labeling, use a print or type size that is prominent, conspicuous and easy to read. Use letters that are at least one-sixteenth (1/16) inch in height based on the lower case letter "o". The letters must not be more than three times as high as they are wide, and the lettering must contrast sufficiently with the background so as to be easy to read. Do not crowd required labeling with artwork or non-required labeling.
Smaller type sizes may be used for information panel labeling on very small food packages as discussed in 21 CFR 101.2(c) & (f).
Different type sizes are specified for the Nutrition Facts label. (see section 7)
The type size requirements for the statement of identity and the net quantity statement are discussed in sections 4 and 5 of this guidance.
Answer: Information that is not required by FDA is considered intervening material and is not permitted to be placed between the required labeling on the information panel (e.g., the UPC bar code is not FDA required labeling). 21 CFR 101.2(e)
Answer: Food labels must list:
- Name and address of the manufacturer, packer or distributor. Unless the name given is the actual manufacturer, it must be accompanied by a qualifying phrase which states the firm's relation to the product (e.g., "manufactured for "or "distributed by");
- Street address if the firm name and address are not listed in a current city directory or telephone book;
- City or town;
- State (or country, if outside the United States); and
- ZIP code (or mailing code used in countries other than the United States).
For questions regarding this document, contact the Center for Food Safety and Applied Nutrition (CFSAN) at 240-402-2371.