Work down this before you order a print run. Every item is a
requirement or a trap, and label reprints are the most avoidable cost in this
category.
The five required elements
1 · Statement of identity
What it is, prominently, on the front.
"Hot sauce", or a brand name plus a descriptor that makes it clear.
Naming a pepper variety makes it a claim about what is in it.
2 · Net quantity
Contents, usually in fluid ounces with metric alongside.
Contents, not container capacity. Note the contrast with honey,
which is sold by WEIGHT because it is denser than water.
3 · Ingredient statement
Every ingredient, descending by weight. Always required.
Unlike a single-ingredient product, a sauce is always multiple
ingredients, so there is no exemption to reach for.
4 · Name and address
Who is responsible for the product, and where.
Street address unless the firm is in a current directory. Packing
under a copacker's roof does not move this obligation.
5 · Allergens
Where a major allergen is present.
Soy, wheat, fish and sesame all appear in this category. Fish sauce
and soy sauce are the ones producers forget.
Placement rules
Identity and net quantity go on the principal display panel. Net quantity sits in
the bottom thirty percent of it, which is the rule most often missed on an otherwise
careful label.
Ingredients, allergens and the name and address may sit on an information panel to
the right of the front.
And the batch code, which is not a labeling requirement in the same sense and is
what makes a recall survivable. On every bottle, tied to the batch record.
Claims that change your obligations
Organic. Certified term. Not available uncertified.
Nutrient content claims such as low sodium have defined meanings
and trigger a nutrition panel regardless of your size.
Any health effect. Offers the product as a drug. Capsaicin has a
research literature and that is not permission to reference it on a condiment.
A floral or varietal claim. Naming a pepper means the sauce must
actually be chiefly that pepper.
State program statements. Cottage food rules often require
their own wording in a specified size, additional to everything above.
References
US Food and Drug Administration.
Food Labeling Guide.
fda.gov21 CFR 101.7,
Declaration of net quantity of contents.
ecfr.gov 