Who makes nutrition facts labels? Understanding the Process

January 5, 2026 •

4 min read

The first US Nutrition Facts label was mandated in 1990 by the Nutrition Labeling and Education Act, but who actually makes nutrition facts labels for the thousands of products on grocery shelves? The answer involves a multi-layered process involving government agencies, food manufacturers, and specialized analysis companies.

Quick Summary

The creation of nutrition facts labels is a collaborative effort between government regulators (FDA, USDA), food manufacturers, and third-party analysis labs.

Key Points

Government Regulation: The FDA primarily regulates nutrition facts labels for most packaged foods, while the USDA handles meat and poultry products.
Manufacturer Responsibility: Food manufacturers are responsible for ensuring their product labels are compliant and accurate, using methods like laboratory analysis or database software.
Analysis Methods: Nutritional information can be obtained through precise lab testing or by using software that calculates values from a database of ingredient information.
Third-Party Services: Many companies hire external food labs or consulting firms to perform nutritional analysis and ensure their labels meet all regulatory standards.
Label Creation Process: The process involves a sequence of steps: recipe formulation, data analysis, compliance verification, and final formatting by a designer.
International Standards: For global products, manufacturers must navigate different labeling requirements, with organizations like Codex Alimentarius providing international guidelines.

The process of creating nutrition facts labels is a comprehensive procedure governed by strict regulations to ensure consumer safety and transparency. It is not created by a single entity, but rather is a collaboration between government regulatory bodies, food manufacturers, and often third-party consultants or software providers.

The Regulators: FDA and USDA

In the United States, the ultimate authority for establishing and enforcing labeling requirements lies with two federal agencies: the Food and Drug Administration (FDA) and the U.S. Department of Agriculture (USDA).

FDA's Role in Labeling

The FDA oversees the vast majority of packaged foods, from cereal and snacks to sodas and canned goods. In 2016, the FDA mandated a significant update to the Nutrition Facts label, reflecting current scientific knowledge on diet and chronic diseases. This update brought changes such as:

Increased prominence for calories and serving size information.
New requirements for displaying "Added Sugars" and Vitamin D.
Updated serving sizes to reflect what people actually eat.
Dual-column labels for packages that may be consumed in one or multiple sittings.

USDA's Authority over Meat and Poultry

The USDA's Food Safety and Inspection Service (FSIS) is responsible for regulating the labeling of meat and poultry products. While the core format is similar to the FDA's, the regulations are distinct, and manufacturers must comply with FSIS-specific requirements for their products.

The Manufacturers: Compiling the Data

While government agencies set the rules, it is the food manufacturers who are responsible for ensuring the accuracy and compliance of the labels on their specific products. To do this, manufacturers can choose from several methods for nutritional analysis:

Laboratory Analysis: The most accurate method involves sending product samples to a certified food laboratory. The lab chemically analyzes the product to determine its exact nutrient composition.
Database Analysis: Companies can use specialized software that pulls data from government databases, such as the USDA's FoodData Central. Manufacturers input their recipe ingredients and quantities, and the software calculates the nutritional profile. This is often a more cost-effective option for small businesses.

The Process in Detail: From Recipe to Reality

The journey of a nutrition label is a multi-step process for manufacturers:

Recipe Formulation: The process begins with the final recipe, which includes the quantity and type of every ingredient.
Nutritional Analysis: Using either a laboratory or software database, the manufacturer obtains the raw nutritional data for the product.
Regulatory Compliance Check: The raw data is then cross-referenced with the latest FDA or USDA regulations regarding rounding rules, serving sizes, and mandatory nutrients.
Label Formatting: The data is formatted into the iconic, standardized Nutrition Facts panel. This is often done by a food labeling specialist or graphic designer.
Review and Approval: The label is reviewed internally and sometimes by third-party experts to ensure full compliance before production. The FDA also randomly tests products to ensure label accuracy.
Printing: The final compliant label is sent to print and applied to the product packaging.

Comparison: Lab Analysis vs. Database Software

For manufacturers, choosing between lab analysis and database software involves weighing cost, accuracy, and efficiency. Here is a comparison:


Aspect	Laboratory Analysis	Database Software
Accuracy	High. Provides exact values for your specific product formulation.	Reliant on the accuracy of the database; may not account for variability in specific ingredients.
Cost	Higher. Can be thousands of dollars per product analysis.	Lower. Subscription-based and significantly cheaper than lab testing.
Time	Longer turnaround time for analysis results.	Instantaneous calculations; labels can be generated quickly.
Suitability	Best for large-scale production, new formulations, or products where precise nutrient levels are critical.	Ideal for startups, small businesses, or products with standard, consistent ingredients.
Flexibility	Less flexible. Re-testing is needed for any recipe changes.	Highly flexible. Easy to adjust recipes and instantly re-calculate nutritional data.

International Standards and Global Variations

For products sold internationally, manufacturers must also adhere to the labeling standards of each country. International bodies like the Food and Agriculture Organization (FAO) and the World Health Organization (WHO) provide guidance to help harmonize these standards globally, but significant variations exist. In the European Union, for example, the label often shows values per 100g or 100ml for easier comparison.

A Collaboration of Expertise

Ultimately, the nutrition facts label is a product of a collaborative ecosystem. The federal government sets the regulatory framework to protect public health. Food scientists and manufacturers then take on the task of accurately analyzing their products and translating that data into the standardized, readable format. Finally, graphic designers ensure the label is legible and fits seamlessly into the product's packaging. This entire process ensures that consumers receive the critical information they need to make informed dietary choices.

For more detailed information on U.S. labeling regulations, visit the FDA's official website.

Frequently Asked Questions

The food manufacturer is ultimately responsible for the accuracy of the nutrition facts label. They must ensure the declared nutrient values comply with the regulatory standards of the country where the product is sold.

The FDA regulates the labeling for most packaged foods, while the USDA, through its Food Safety and Inspection Service (FSIS), regulates the labeling of meat and poultry products.

Manufacturers typically use one of two methods: sending product samples to a certified laboratory for chemical analysis or using specialized software with a database of ingredient nutritional information.

Yes, small businesses can use nutrition analysis software to generate compliant labels. This method is often more affordable and efficient than using a lab for every product.

Third-party services, such as food labs and compliance consultants, assist manufacturers by providing expert nutritional analysis, regulatory guidance, and label formatting to ensure accuracy and compliance.

While each country has specific regulations, international organizations like the Codex Alimentarius Commission provide guidelines to harmonize food labeling standards across different countries.

The most recent major changes to the US Nutrition Facts label were finalized by the FDA in 2016, with compliance deadlines in 2020 and 2021 for manufacturers of different sizes.