Which foods do not require a label? Understanding the exemptions

January 6, 2026 •

3 min read

According to the U.S. Food and Drug Administration (FDA), numerous foods are exempt from standard nutrition labeling requirements under specific conditions. Understanding which foods do not require a label is vital for consumers seeking transparency and for businesses aiming for regulatory compliance. This guide breaks down the rules surrounding these often-unlabeled food products.

Quick Summary

A detailed overview of federal food labeling exemptions for various products and scenarios, including raw produce, items prepared on-site at retail, small-batch goods, and foods with minimal nutritional value. Key regulatory reasons for these exemptions are also explained.

Key Points

Raw Foods: Fresh, whole fruits and vegetables, as well as single-ingredient raw meats and seafood, are typically exempt from standard nutrition labeling.
In-Store Prepared Meals: Foods prepared and sold for immediate consumption at the same retail location, like a bakery or deli, do not require a label.
Small Business Exemption: Small-batch food producers, such as those at farmers' markets, are often exempt if they meet specific criteria for annual sales or units sold.
Nutritionally Insignificant Items: Products like plain coffee, tea, and spices, which offer negligible nutritional value, are not required to be labeled.
Bulk or Small Items: Unpackaged bulk foods and products in very small packages (less than 25 cm² surface area) may not require individual labels.
Immediate Consumption: Individual servings of foods sold for immediate consumption, such as a deli sandwich, are exempt from nutrition labeling.

Understanding Food Labeling Exemptions

While most packaged food sold in the United States requires a Nutrition Facts label, federal regulations make numerous exceptions. These exemptions are not random; they are typically based on factors like the food's nutritional significance, level of processing, method of sale, and the size of the manufacturing business. The regulations aim to provide consumers with useful information while not placing an undue burden on small producers or retailers.

Raw Agricultural Commodities

One of the most significant categories of exemption is for raw agricultural commodities. This includes fresh, whole, or cut fruits and vegetables that have not been significantly processed. The reasoning is that the nutritional content of these single-ingredient products is generally understood by consumers. Examples include:

Whole apples, oranges, and bananas
Raw broccoli florets and carrots
Fresh, unpackaged lettuce
Raw, single-ingredient fish or seafood
Fresh, single-ingredient meat and poultry, excluding ground versions

Foods Prepared at Retail Establishments

Foods prepared and sold at the same retail location are frequently exempt from standard labeling rules. This covers a wide variety of items consumers encounter daily. The logic here is that the retailer can provide ingredient or nutritional information upon request, or that the nature of the product makes a pre-printed label impractical.

Deli Counters: Packaged meats and cheeses cut for a customer at a deli counter.
Bakeries: Fresh-baked bread, pastries, and cakes prepared and sold on the premises.
Restaurant Meals: Food sold for immediate consumption in a restaurant setting.
Salad Bars and Hot Bars: Bulk food items served from assisted or self-service display cases.

Products from Small Businesses

Small food manufacturers, including cottage food producers and vendors at farmers' markets, may qualify for exemptions under specific conditions. These exemptions help reduce the regulatory burden on small enterprises. Qualification often depends on meeting certain thresholds for annual food sales or units sold. However, if a small business makes a nutritional claim about its product (e.g., "low-fat"), it forfeits the exemption and must provide full nutrition labeling. This is an important distinction for businesses and consumers alike.

Foods with Insignificant Nutritional Value

Some foods are exempt because they contain insignificant amounts of all mandatory nutrients required for a Nutrition Facts panel. This category covers products that are typically consumed in small quantities and do not contribute meaningfully to daily nutritional intake.

Plain coffee and tea
Spices and herbs
Unflavored, unsweetened water
Food additives and flavorings
Pure, natural salt

Comparison Table: Labeled vs. Unlabeled Foods


Feature	Typically Labeled Foods	Typically Unlabeled Foods	Reason for Difference
Processing	Canned, frozen, pre-mixed, or processed items	Raw, whole, or minimally-processed items	Processing adds ingredients and changes nutritional composition.
Point of Sale	Mass-produced items sold through retailers	Foods made and sold at the same establishment	Practicality; information can be provided on request for on-site items.
Business Size	Large-scale commercial food manufacturers	Small businesses, farmers' market vendors	Small business exemption applies below certain revenue or volume thresholds.
Nutritional Content	Products with significant nutrient profiles	Items with negligible nutrients (spices, coffee)	No significant nutrient information to report for minimally-nutritious items.
Packaging	Standard, pre-packaged containers	Bulk containers or very small packages (<25cm²)	Not practical for bulk containers; surface area too small for tiny packages.

The Importance of Knowing What's Exempt

For consumers, understanding these exemptions helps contextualize the information (or lack thereof) on their food. You won't find a Nutrition Facts panel on a bunch of bananas or a fresh sandwich made at a local cafe, but that's a standard practice, not a regulatory lapse. For businesses, knowing the rules helps avoid costly mistakes and ensures compliance with federal guidelines. For more detailed information on regulations and exemptions, a business can consult the official guidance provided by the FDA.

Conclusion

While the sight of unlabelled food might seem unusual in a highly regulated market, it is a common and legal practice for many products. The exemptions are a practical and sensible approach to food labeling, balancing consumer access to information with the operational realities of different food production and sales scenarios. By recognizing the categories that allow which foods do not require a label, both shoppers and businesses can better navigate the complexities of food regulations with confidence.

Food Labeling Guide (PDF) | FDA

Frequently Asked Questions

No, raw, fresh, whole, or cut fruits and vegetables are considered single-ingredient foods and are exempt from standard nutrition labeling requirements. However, some retailers may voluntarily provide nutritional information.

Food served for immediate consumption at a restaurant or similar commercial enterprise is typically exempt from individual labeling. Some larger restaurant chains may voluntarily provide calorie or nutrition information on menus or upon request, but it is not a widespread requirement for all items.

Spices, herbs, plain coffee, and tea are exempt because they contain insignificant amounts of all mandatory nutrients. They are typically used in small quantities and do not significantly contribute to overall dietary intake.

Products sold by individual producers at farmers' markets or roadside stands are often exempt, particularly small-batch or 'cottage' foods. However, local rules may vary, and any product making a nutritional claim must be labeled.

No, a sandwich prepared and packaged at a deli counter for immediate consumption is typically exempt. The ingredients should be available upon request, and allergens must still be managed and communicated.

The small business exemption applies to manufacturers with very low annual food sales or units sold. This exemption is designed to alleviate the cost and complexity of labeling for very small enterprises. The business must file proper notice with the FDA to qualify.

Unpackaged foods sold in bulk containers do not require individual labels. The retailer is generally required to display ingredient and allergen information on a card or sign near the product.