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The panel

What counts as the panel

On this page11
Surface area is not panel area. The difference is where this goes wrong.

The table keys on the principal display panel

Which is the part of the label most likely to be displayed, shown or examined under customary conditions of display for sale. Not the total surface of the container.

So a shoulder is not panel

Nor a taper, nor a base, nor the part of a wrap that disappears round the back. The panel is what faces a buyer.

Which makes shape decisive

Two containers of the same volume can sit in different bands of the table because one is a straight cylinder and the other is a tapered oval.

Measure it rather than estimating

Height of the printable straight wall times the width that faces forward. It is arithmetic and it takes a minute, and the band boundaries are close enough together that estimating is risky.

A small container is a hard label

17 containers at 15 mL or under and 77 at 60 or under on this shelf. Those have tiny panels and still have to carry everything the Act requires.

Which is the case for a carton or a tag

If the required text will not fit legibly on the panel at the height the table demands, the information has to go somewhere that can carry it.

And the warning cannot be relegated

The provision is about prominence, placement and conspicuousness. Putting the signal word on the back while the front carries branding is the thing the section exists to prevent.

Jars have a different problem

173 jars on this shelf. A short wide jar has a large lid and a shallow wall, so the panel can be smaller than the container suggests.

Tubs are worse again

17 tubs and pails. A tapered tub's printable wall is short and the lid is usually not the principal display panel at point of sale.

Decide the panel before the artwork

Panel area, band, minimum heights, then design. Every other order ends with a designer being asked to make a warning smaller, which is the one thing that cannot be done.

References

16 CFR 1500.121, Table 1, minimum type size by area of the principal display panel, where type size is "the actual height of the printed image of each upper case or capital letter as it appears on the label". For the signal word: 3/64 inch for a panel of 0 to 2 square inches; 1/16 inch for over 2 to 5; 3/32 inch for over 5 to 10; 7/64 inch for over 10 to 15; 1/8 inch for over 15 to 30; and 5/32 inch for over 30. For the statement of hazard: 3/64 inch up to 5 square inches; 1/16 inch for over 5 to 10; 3/32 inch for over 10 to 30; and 7/64 inch for over 30. law.cornell.edu
The Davis Pack Supply catalog, measured 19 October 2026. The cycling and climbing shelf is 972 rows: 383 containers and 589 closures. 5 mL to 2,000 mL with a median of 237; 17 containers at 15 mL or under, 25 at 30 or under, 77 at 60 or under, 132 at 120 or under. 174 HDPE, 147 PET, 42 PP, 20 glass. 188 bottles, 173 jars, 17 tubs and pails, 3 jugs, 2 tubes. 137 white, 72 clear, 69 natural, 37 black, 33 amber. Closures: 381 continuous thread, 39 child resistant, 36 disc top, 26 dome lids, 26 spouted, 19 flip top, 13 spice caps, 11 liners and sealing discs, 9 phenolic.
Written from 16 CFR 1500.121 and 1500.14, and from the catalog as it stood on 19 October 2026. Whether a given lubricant or sealant is a hazardous substance under the Act is the formulator's determination, not ours. No point-size conversions appear here because the regulation specifies fractional inches as the height of a capital letter. Climbing area rules on chalk are set by land managers and vary site by site.