When you need a nutrition panel

Most small producers do not need a nutrition panel, and several things they might do would change that.

The small business exemption

Federal rules provide exemptions for small businesses based on employee count and units sold, and there is a notice to file to claim one. The thresholds are specific and they are the thing to check against your own numbers rather than assume.

The exemption is not automatic in the sense of requiring nothing from you. It is a claim you make, and it has conditions.

What removes the exemption

Making a nutrient content claim. Calling a sauce low sodium, sugar free or a good source of anything requires the panel regardless of your size, and those phrases are easy to use casually on a label.

Growing past the thresholds. And selling into accounts that require a panel as a condition of listing, which many grocery buyers do irrespective of the regulation.

Getting the numbers

Two routes. A laboratory analysis of the finished product, which is accurate and costs more. Or a database calculation from the recipe by a qualified provider, which is cheaper and accepted for many products.

Either way it is per formulation. Six sauces is six analyzes, which is the same pattern as the process filings and the same surprise when a line expands.

What it costs to get wrong

A panel with wrong numbers is worse than no panel, because it is a specific misstatement rather than an omission. Serving size in particular is defined by regulation for a category and is not yours to choose.

If you are close to needing one, get it before a buyer asks rather than after. Turnaround is weeks and a listing conversation does not usually wait.

References