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Surface area

Two thresholds

By Dwight Davis, Founder

On this page13
4.5 point and 6 point. A point and a half between the bands.

Below 12 square inches

All information within the nutrition label is in type no smaller than 4.5 point. The smallest permitted setting, for the smallest packages.

From 12 to 40 square inches

No smaller than 6 point. A point and a half larger, across a band that covers a more than threefold range of area.

Above 40 square inches

The small and intermediate package provisions are not the governing ones, and the general type size rules for the panel apply instead. Those are not quoted on these pages.

Which means the bands are relief provisions

They exist to let a small package carry the panel at all. A larger container does not need relief and does not get these allowances.

So smaller is not simpler here

A small package gets a smaller permitted type and a harder layout. The relief is permission to shrink, not permission to omit.

The 12 square inch line is low

A cylinder 2 inches across and 2 inches tall has a side wall of about 12.6 square inches. So almost any jar clears it.

And none of our 147 measurable containers is below it

The smallest is 12.06 square inches on the side wall alone, which with the lid and base counted is comfortably over 12.

The 40 square inch line is the live one for us

91 of 147 containers sit in the 12 to 40 band on our side-wall figure and 56 are over 40.

Which makes it the boundary to check

A container our figure puts at 35 square inches may be over 40 in the regulation's own measure, because the regulation counts more surface than we do.

The bands are about the nutrition label specifically

The type size floors apply to all information within the nutrition label. Other required statements on the package have their own rules and are not quoted here.

So the panel and the rest of the label are budgeted separately

Which matters on a container near a boundary, because the panel may be entitled to shrink while the surrounding text is not.

Erring toward the smaller band is the safe direction

Designing to 6 point when you are entitled to more is permitted. The other way round is not.

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.