What are the exemptions for nutrition labeling?

January 6, 2026 •

4 min read

According to the Food and Drug Administration (FDA), many foods are not required to carry a nutrition facts panel. This article explores the specific criteria and categories that determine what are the exemptions for nutrition labeling, providing clarity for both businesses and consumers.

Quick Summary

Several types of food and specific businesses can be exempt from mandatory nutrition labeling requirements, based on factors like product type, company size, and preparation method. These exemptions cover items from fresh produce to products with insignificant nutritional value.

Key Points

Single-Ingredient Products: Unprocessed, single-ingredient foods like raw fruits, vegetables, and meat are typically exempt from mandatory nutrition labels.
Insignificant Nutrients: Products with insignificant amounts of all mandatory nutrients, such as spices, tea, coffee, and bottled water, do not require a label.
Small Business Exemption: Small manufacturers meeting specific thresholds for annual sales and number of employees can claim an exemption, often requiring an annual notice to the FDA.
Prepared On-Site: Foods prepared and sold in the same retail establishment, like deli salads or bakery bread, can be exempt from full labeling requirements.
Labeling Claims Override: Making any nutrition-related claim on a product's packaging invalidates the exemption, requiring a full nutrition facts panel.
Small Package Exemption: Products in packages too small to display a standard nutrition facts panel may be exempt, though alternatives like point-of-sale information might be required.

Introduction to Nutrition Labeling Exemptions

Food regulations, such as those enforced by the FDA in the United States, aim to ensure transparency and consistency in the food supply. However, a one-size-fits-all approach is often impractical. For this reason, specific exemptions to mandatory nutrition labeling have been created to accommodate different products and business models. These exemptions are not a loophole but are based on logical considerations, such as a food's inherent nature, minimal nutritional contribution, or practical limitations for small-scale producers.

Exemptions Based on Product Type

Many foods are exempt from carrying a nutrition label because of their minimal processing or negligible nutritional content. This category is based on the premise that a nutrition panel for these items would provide no useful information to the consumer. For example, fresh, unprocessed items like whole fruits and vegetables, herbs, spices, and tea leaves are exempt. The FDA and other regulatory bodies, like the Canadian Food Inspection Agency, recognize that these items are single-ingredient and their nutritional value is generally known or non-existent in small serving sizes.

Other notable product-based exemptions include:

Coffee and Tea: Plain, roasted coffee beans or tea leaves are exempt unless other ingredients are added. This does not apply to flavored coffees or ready-to-drink options with added sugars or other ingredients.
Waters: Bottled water that contains only water, carbon dioxide, and flavorings (that do not change nutritional value) is typically exempt.
Spices and Flavorings: Herbs, spices, and flavor extracts with negligible nutritional value per serving are exempt.
Prepared on-site foods: Food prepared and processed at the same retail establishment where it is sold, such as fresh bakery bread or deli items, are often exempt from a full nutrition facts table.
Small packages: Foods sold in very small containers, where there is insufficient space to accommodate a label, can be exempt. However, these products may still be required to provide nutrition information through other means, such as on a website or at the point of sale.

Exemptions for Small Businesses

Small businesses, such as family-run bakeries or specialty food producers, often receive specific exemptions to alleviate the financial and administrative burden of compliance. These exemptions are a critical part of supporting smaller food manufacturers. Eligibility for these exemptions often depends on a business's annual revenue and the number of units sold. In the US, small businesses can file a notice annually with the FDA to claim an exemption, provided they meet certain criteria. If, however, a small business makes a nutrition-related claim on their packaging, such as “low fat,” the exemption is void, and they must provide full nutritional information.

Foods with Insignificant Nutrient Contribution

Another common exemption applies to foods that provide insignificant amounts of all mandatory nutrients per serving. The nutrients in question must be small enough to be listed as zero on a nutrition label, after applying specific rounding rules. Examples include certain spices, food colorings, and plain coffee. However, if the product contains even one nutrient in a significant amount, it may not qualify for this exemption.

Comparison Table: Common Exemptions vs. Standard Requirements


Feature	Exempt Foods (Example: Spices)	Standard Packaged Foods (Example: Cereal)
Requirement for Nutrition Label	Not mandatory if nutrients are insignificant.	Mandatory, must display the Nutrition Facts panel.
Basis for Exemption	Insignificant nutritional value per serving.	No exemption for significant nutrient sources.
Small Business Impact	Easier regulatory burden, no annual filing needed unless sales thresholds exceeded or voluntary claims made.	Compliance required, including potential lab testing for nutrient analysis.
Label Claim Impact	Exemption is lost if a nutrition claim is made on the packaging.	Must provide full nutrient information to back up any claims.
Fresh Produce Rules	Generally exempt if whole and unprocessed.	Not applicable, as typically sold in this form.
Preparation Location	Not a factor for prepackaged exempt items.	Exemption may apply if prepared and sold at the same retail establishment.

Conclusion: Navigating Labeling Regulations

Understanding what are the exemptions for nutrition labeling is essential for food manufacturers and small businesses to ensure compliance with federal and international regulations. These exemptions are designed to create a more level playing field, reducing the regulatory load on small-scale producers and for products where nutritional information is not relevant. However, businesses must remain vigilant, as making a nutritional claim, even on an otherwise exempt product, immediately invalidates the exemption. For the consumer, these rules explain why some items, like a bag of apples or a jar of spices, do not carry a full nutrition panel while a multi-ingredient packaged meal does. To be certain of any requirements, businesses should consult the latest FDA guidance for specific product types and circumstances.

For more detailed information on US food labeling laws, the FDA provides a comprehensive guide on their website.

Frequently Asked Questions

Not always. Small businesses with limited sales or a small number of employees may qualify for an exemption from mandatory nutrition labeling. The criteria often involve filing an annual notice with the FDA if sales volumes exceed a certain limit, though an exemption is voided if a nutritional claim is made.

No, raw, unprocessed, single-ingredient fresh fruits and vegetables are typically exempt from mandatory nutrition labeling. The nutritional information is often assumed to be known by consumers.

Plain, unflavored coffee and tea that contribute insignificant amounts of all mandatory nutrients per serving are exempt. However, flavored coffee or tea products with added sweeteners or other ingredients generally require a label.

Yes, in many cases. Foods that are prepared and packaged on the same retail premises where they are sold, such as a deli sandwich or fresh bakery goods, are often exempt from full nutrition labeling requirements.

If a company makes any kind of nutrition or health claim on an otherwise exempt food product, the exemption is automatically voided. In this scenario, the product must be fully labeled with a nutrition facts panel.

Yes, spices, herbs, and flavor extracts are generally exempt because they provide an insignificant amount of nutrients per serving. This exemption applies as long as no nutritional claim is made on the packaging.

This exemption applies to food items sold in very small packages where there is not enough surface area to adequately display a full nutrition facts panel. For some jurisdictions, like the EU, this applies to packages with a largest surface area of less than 25 cm².