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Getting started

The whole container, not the panel

On this page11
Every other rule measures a panel. This one measures the package.

The measure

Total surface area available to bear labeling. Not the principal display panel, not the information panel, and not a proportion of the label.

Two thresholds

Under 12 square inches, the information in the nutrition label is no smaller than 4.5 point. From 12 to 40 square inches, no smaller than 6 point.

Which is the fifth distinct kind of label rule in this library

The cycling property scales type size with principal display panel area. The hair care property gives a panel a proportion of the label. The topicals property has a flat floor. The beer property bands by container volume and caps characters per inch.

And this one is the only whole-package measure

Which matters because a tall narrow jar and a squat wide one with the same panel can have very different total areas, and the rule follows the total.

It also permits the panel to degrade

Where space is constrained, the hairlines may be omitted and replaced by a row of dots connecting the columns. Most rules set a floor and stop.

So legibility wins over structure

The regulation would rather you kept the type readable and lost the table rules than compressed the type to preserve them.

Our shelf straddles the upper threshold

Side-wall area is computable on 147 of 163 containers, and it runs 12.06 to 84.25 square inches with a median of 33.4.

91 in the band, 56 above it

And none below 12 square inches. So the 40 square inch boundary sits in the middle of this shelf and the 12 square inch one is off the bottom of it.

The smallest clears 12 by six hundredths of an inch

An 88.7 mL PET jar, 2.875 inches across and 1.335 tall, at 12.06 square inches. The same shape of near miss as the cider bottle that clears a standard of fill by 9.764 millilitres.

Our figure is a lower bound

It is the cylinder side wall and the regulation measures more than that. Which is enough to answer whether a container has cleared a band, and that is the question.

References

21 CFR 101.36(i), on the Supplement Facts label: "All information within the nutrition label on small-sized packages, which have a total surface area available to labeling of less than 12 square inches, shall be in type size no smaller than 4.5 point", and "packages, which have from 12 to 40 square inches of surface area available to bear labeling, shall be in type size no smaller than 6 point". The same paragraph provides that where space is constrained "the hairlines may be omitted and replaced by a row of dots connecting the columns". law.cornell.edu
The Davis Pack Supply catalog, measured 19 October 2026. Height and diameter are both published on 147 of the 163 containers in this group, which allows the cylindrical side-wall area to be computed. It runs 12.06 to 84.25 square inches with a median of 33.4: none under 12 square inches, 91 in the 12 to 40 band and 56 over 40. The smallest is an 88.7 mL PET single wall jar, 2.875 inches across and 1.335 inches tall, at 12.06 square inches. These figures are the side wall only and are therefore a lower bound on the regulation's measure, which is the total surface area available to bear labeling.
Written from 21 CFR 101.36 and from the catalog as it stood on 19 October 2026. The surface area figures here are computed from published height and diameter and are the cylindrical side wall only, which is a lower bound: the regulation measures the total surface area available to bear labeling, and that is more. Nothing on these pages sets out what a Supplement Facts panel must contain, which ingredients may be used, or what claims are permitted. A dietary supplement's serving size is determined by reference to the amounts in 21 CFR 101.12(b) rather than by the maker.