Do I need a Nutrition Facts panel on my jam?

Probably not, as long as you stay small and make no nutrition claims. FDA exempts low-volume products from a firm with fewer than 100 full-time equivalent employees that sells fewer than 100,000 units of the product a year in the United States, with an annual notice; a firm with fewer than 10 employees selling fewer than 10,000 units of a product does not even file the notice [1][2]. Separate exemptions cover small retailers [1]. The catch is claims: put "reduced sugar," "sugar free" or any other nutrition claim on the jar and the exemption is gone for that product [2]. This page walks the decision and explains how to get a panel made when you need one.

Answer four questions in order

1. Do you, or will you, put any nutrition claim on the label, website or ads? If yes, stop here: you need a Nutrition Facts panel for that product. FDA's exemption page says low-volume products "that bear nutrition claims do not qualify" [1], and its exemption guide says any nutrient content claim, health claim or other nutrition information on the label, in labeling or in advertising makes the exemption inapplicable [2]. "Sugar free" is FDA's own example [2]. The claims jam makers reach for are covered below.

2. Are you an importer? The no-notice route for the smallest firms is written for non-importers [2]. If you import any of your products, read FDA's exemption guide for the rules that apply to you.

3. Do you have fewer than 10 full-time equivalent employees, and does this product sell fewer than 10,000 units a year in the U.S.? If yes to both, no notice is needed [2].

4. If not, do you have fewer than 100 full-time equivalents and fewer than 100,000 units of this product a year? If yes, you are exempt, but you must file a notice with FDA every year [1][2]. If no, you need the panel.

Most cottage jam makers answer "no claims, not an importer, under 10 and under 10,000" and need neither a panel nor a notice. A business growing into wholesale may cross 10,000 units of its best seller before it notices, so count.

The exemptions side by side

All figures are from FDA's pages, current as of October 5, 2026 [1][2].

FDA's pages do not say whether a cottage producer selling its own jam directly at a farmers market counts as a "retailer" for the third route [2]. If you want to rely on it, ask FDA rather than assume. For most makers the low-volume routes are the clearer path anyway.

How FDA counts employees and units

The count is per product, and the definitions matter.

• A full-time equivalent is total paid hours for your firm and its affiliates divided by 2,080. A firm with fewer than 100 actual employees may report its actual headcount instead [2]. Seasonal help counts by hours.
• A unit is "a package, or if unpackaged, the form in which the product is offered for sale to consumers" [2]. One jar is one unit, whatever its size.
• A product is a food in any size package with the same statement of identity and similar preparation, from one manufacturer or sharing a brand name. Products with different ingredients count separately [2]. FDA's guide does not say directly whether each flavor is a separate product; because flavors have different ingredients, the reading most consistent with the guide counts strawberry and apricot separately. Confirm with FDA if you are close to a threshold.
• The 12 months run from the date on your notice, and renewals reuse the same dates [2]. For a new product, the count is your estimate from when U.S. sales are expected to begin [2].

Filing the notice

The notice gives your firm's legal name and contacts, the type of firm, the 12-month period, your average FTE count, the units sold by product, who made and distributed each product, a contact person and a signed certification [2]. By signing, you commit to telling FDA if you exceed the thresholds [2]. From October 5, 2026, web submissions go through FDA Industry Systems; paper notices by mail or fax on the model form are still accepted [1].

Claims that cost you the exemption

The words jam makers most often want to use are nutrient content claims with federal definitions.

The reference amount for jam is set in FDA's table of serving sizes: the category "Honey, jams, jellies, fruit butter, molasses, fruit pastes, fruit chutneys" has a reference amount of "1 tbsp," with the label statement "1 tbsp (__ g); 1 tbsp (15 mL)" [4]. Any reduced-sugar comparison is made per tablespoon.

The practical consequence for low-sugar products: you can sell a low-sugar pectin spread under the name "Strawberry Fruit Spread" and keep the exemption, but the moment the label says "reduced sugar" or "50 percent less sugar," you need a full panel and the data behind the comparison. Naming is on what you can call your jam.

When you need a panel: getting one made

If you make a claim, cross a threshold, or a store buyer insists on one, you have three routes:

1. Recipe analysis with nutrition software or a labeling service. The service takes your formula by weight and calculates the panel from ingredient data. Give it weights, not cups, and tell it your cooked yield so it accounts for water boiled off. Jam loses a lot of water in the pan, and a calculation that ignores that will understate sugar per tablespoon.
2. Laboratory analysis of finished jars. Slower and more expensive, but it measures what is actually in the jar.
3. A food science extension program in your state. Some university programs offer labeling help or can point you to a service.

Whichever you use, keep the formula fixed. A panel describes one recipe; change the fruit-to-sugar ratio and the panel is out of date. Ask for the serving size to be stated as 1 tbsp with its gram weight [4], and have the service lay out the format, which is set out in FDA's nutrition labeling rule, 21 CFR 101.9.

Make the rest of the label right first

A Nutrition Facts panel sits on the information panel alongside your ingredient list and address. If you have not settled those, start with what a jam label must say. If you are heading into stores, selling jam to shops and cafes covers what buyers ask for, and FDA registration and food safety rules covers the obligations that arrive with a licensed kitchen.

References

1. U.S. Food and Drug Administration, Small Business Nutrition Labeling Exemption, content current as of October 5, 2026. https://www.fda.gov/food/labeling-nutrition-guidance-documents-regulatory-information/small-business-nutrition-labeling-exemption
2. U.S. Food and Drug Administration, Small Business Nutrition Labeling Exemption Guide, content current as of October 5, 2026. https://www.fda.gov/food/labeling-nutrition-guidance-documents-regulatory-information/small-business-nutrition-labeling-exemption-guide
3. eCFR, 21 CFR 101.60, Nutrient content claims for the calorie content of foods, paragraph (c), sugar content claims, up to date as of October 20, 2026. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-D/section-101.60
4. eCFR, 21 CFR 101.12, Reference amounts customarily consumed per eating occasion, Table 2, Sugars and Sweets, up to date as of October 20, 2026. https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-101/subpart-A/section-101.12