FDA Front of Package Nutrition Labeling: 2026 Guide

Front of package nutrition labeling in the United States is still proposed, not required. FDA proposed its "Nutrition Info" box on 16 January 2025, but the rule has not been finalized. As of today, no packaged food in the United States is required to carry the box, and no compliance clock is running.

This guide explains the FDA front of package nutrition label as proposed, including what the box would show, the Low, Med and High thresholds, placement and formatting, exemptions, the proposed compliance timeline, and what manufacturers can usefully do while the rule remains pending.

This is the hub page for the cluster. For nutrient-by-nutrient detail on sodium, added sugars and saturated fat in the proposed box, see front of package label requirements. It does not cover the Nutrition Facts panel itself, which is a separate and long-binding rule.

Where FDA front of package nutrition labeling stands

FDA published "Food Labeling: Front-of-Package Nutrition Information" in the Federal Register on 16 January 2025 at 90 FR 5426, under Docket No. FDA-2024-N-2910 and RIN 0910-AI80.

The proposal would create a new 21 CFR 101.6, "Front-of-package Nutrition Info box." Everything described below comes from that proposal. None of it is currently in force.

Date	What happened
16 Jan 2025	Proposed rule published, 90 FR 5426, docket FDA-2024-N-2910. FDA had announced it on 14 January 2025.
20 Jan 2025	Presidential "Regulatory Freeze Pending Review" memo; the proposal became subject to review by the incoming administration.
9 May 2025	Comment period extension published, moving the 16 May 2025 deadline to 15 July 2025.
15 Jul 2025	Comments closed. Trade press reported more than 11,000 comments; FDA itself later described "tens of thousands of public comments" showing broad support but varying views on the label's content and design.
2025 and 2026 Unified Agendas	RIN 0910-AI80 listed at Final Rule Stage with a projected final rule date of May 2026. That date passed with no final rule.
23 Jan 2026	FDA's Human Foods Program 2026 priority deliverables listed "enhanced food labeling, such as front-of-package nutrition labeling," with FDA to analyse comments and prepare options for a final rule.
March 2026	Then-Commissioner Makary said leadership "did not like the front-of-package plan that we inherited." Deputy Commissioner Diamantas told Bloomberg Law "everything is on the table," and that meaningful changes could require re-proposing the rule for another comment round.
12 May 2026	Makary resigned; Kyle Diamantas, previously Deputy Commissioner for Human Foods, became Acting FDA Commissioner.
July 2026	The 2026 Unified Regulatory Agenda again listed it as a priority final rule "anticipated for remainder of 2026," with no date commitment.
Today	No final rule. A Federal Register search for FDA "front-of-package" documents from 2025 forward returns only the January 2025 proposal and the May 2025 extension.

That leaves three possible paths rather than one. FDA could finalize the rule broadly as proposed, re-propose it with changes and open another comment period, or allow the rulemaking to go nowhere. Anyone saying the final design is already settled is guessing.

What the FDA Nutrition Info box would show

The proposed Nutrition Info box is deliberately narrow. Under proposed 21 CFR 101.6(a)(2), it would contain:

• The heading "Nutrition Info" across the top, in larger type than anything else in the box.
• Two column subheadings: "Per serving," with the serving size in household measure, such as "Per serving (1/2 cup)" or "Per serving (whole package)," and "% Daily Value."
• Three nutrients in a fixed vertical order: Saturated Fat, Sodium, then Added Sugars.
• For each nutrient, its quantitative %DV in one column and, to the right, one interpretive word: Low, Med or High.
• A banner at the bottom carrying an "FDA.gov" attribution.

Proposed 101.6(a)(4) would prohibit anything else from appearing inside the box.

Two omissions surprise people. First, calories are not in the box, although calories could still be declared elsewhere on the front panel under existing rules. Second, there is no fiber, protein or vitamin line. The proposed box is a three-nutrient summary, not a complete nutrition profile.

The %DV figures are not new calculations. They are the same %DVs already calculated and rounded for the Nutrition Facts panel under 21 CFR 101.9(c)(9) and (d)(7)(ii), for ages 4 and older. FDA said the proposal does not address calculation or rounding. If your Nutrition Facts panel is correct, the inputs for the proposed box are already correct.

Low, Med and High in grams and milligrams

Proposed 101.6(a)(2)(iv) creates three bands based entirely on %DV:

• Low: 5% DV or less.
• Med: 6% to 19% DV.
• High: 20% DV or more.

These cutoffs use the 5/20 rule FDA already applies in consumer education.

Because the adult Daily Values are 20 g saturated fat, 2,300 mg sodium and 50 g added sugars, those percentages can be translated into absolute amounts per serving.

The proposed regulation does not state these gram and milligram figures. They are arithmetic derived from the DVs, but they are the numbers formulators actually work with.

Nutrient (adult DV)	Low (5% DV or less)	Med (6% to 19% DV)	High (20% DV or more)
Saturated Fat (20 g)	1 g or less per serving	Above 1 g and below 4 g	4 g or more per serving
Sodium (2,300 mg)	115 mg or less per serving	Above 115 mg and below 460 mg	460 mg or more per serving
Added Sugars (50 g)	2.5 g or less per serving	Above 2.5 g and below 10 g	10 g or more per serving

Consider a 1/2 cup serving of pasta sauce containing 1 g saturated fat, 480 mg sodium and 7 g added sugars. Those amounts calculate to 5%, 21% and 14% DV, so the proposed box would read Low, High, Med.

Reducing sodium to 450 mg still produces 20% DV and therefore still prints High. You need to get below 460 mg to reach 19% and print Med. That narrow step illustrates the kind of reformulation decision the box could drive.

Front of package nutrition labeling format, type size and placement

Proposed 101.6(a)(3) specifies how the box would appear. It is not the color-coded traffic-light system used by some front of pack labeling schemes in other countries.

• Placement: The upper third of the principal display panel. FDA did not propose an exact position within that area.
• Type size: At least 8 point and no smaller than the required net quantity of contents declaration under 21 CFR 101.7(h) and (i), using a single, easy-to-read type style.
• Colour: All text and hairlines in black or one color on a white or other neutral contrasting background. FDA's testing found monochrome versions performed well, so the proposal uses a black-and-white box.
• Rules and weights: A hairline outer box, thick horizontal rule below the heading and subheadings, and hairline rules between nutrient rows.
• Emphasis: "Nutrition Info" extra-bold and centered, "% Daily Value" extra-bold and right-justified, nutrient names bold and left-justified, Low, Med and High extra-bold and right-justified, and %DV figures right-justified in their own column.
• FDA.gov banner: A background in the same color as the text, with "FDA.gov" right-justified in bold or extra-bold using the same color as the box background, creating a reversed-out strip.

For most brands, the practical challenge is not drawing the box. It is the upper-third placement requirement, which competes with brand marks, flag callouts and net weight statements. That is where much of the potential redesign cost sits.

Scope, exemptions and the small-package Nutrition Info box

The proposal would apply to food covered by 21 CFR 101.9 and marketed for people ages 4 and older.

Foods marketed for infants and children under 4 would not be covered, although FDA asked for comment on future policy for ages 1 to 3. Most dietary supplements would also fall outside the requirement because they are labeled under 21 CFR 101.36 and exempt from 101.9 through 101.9(j)(6).

Proposed 101.6(c) would exempt:

• Foods already exempt from 101.9 under 101.9(j), unless stated otherwise.
• Small packages with less than 12 square inches of total surface area available to bear labeling.
• Packages marketed as gifts containing an assortment of foods.
• Unit containers inside a multiunit retail package where the units are exempt under 101.9(j)(15) and the outer package carries the box.

Several special cases matter for real product lines:

• Intermediate packages, 40 square inches or less of labeling area: A reduced box would drop the "Per serving" and "% Daily Value" subheadings and the numeric %DVs. It would show only the interpretive words, using the abbreviations "Sat. Fat" and "Add. Sugar."
• Aggregate displays such as variety packs: One box per product, arranged horizontally or vertically in the upper third, with each food name right-justified above its box.
• Dual-column per serving / per unit products: The box would reflect "per serving."
• As-packaged versus as-prepared: The box would reflect the product as packaged and carry a statement such as "Represents product as packaged" or "See Nutrition Facts for As Prepared information."
• Two population groups: The box would reflect ages 4 and older only.
• Bulk foods: The box would appear on bulk container labeling visible at the point of purchase.
• State law: Proposed 101.6(d) would preempt non-identical state front-of-package requirements, a quiet but consequential provision.

The proposed change to the "low sodium" claim

The same proposal would amend nutrient content claim rules, and this is the part most likely to catch a manufacturer out.

FDA proposed lowering the threshold for "low sodium" from 140 mg to 115 mg or less per RACC. Where the RACC is 30 g or less or 2 tablespoons or less, the proposed threshold is 115 mg or less per 50 g. For meals and main dishes, it would be 115 mg or less per 100 g.

The reason is alignment. 115 mg equals 5% of the 2,300 mg sodium DV, so the "low sodium" claim would match the proposed "Low" band.

The binding definition today remains 140 mg under 21 CFR 101.61. Nothing has changed.

If your product contains between 116 mg and 140 mg per RACC, it can qualify for "low sodium" today but would stop qualifying if the proposal were finalized as written. That is an identifiable exposure you can measure now from your formulation sheet or by running the product through the claim validator using the current 140 mg definition.

"Low saturated fat" would retain its existing thresholds: 1 g or less per RACC and no more than 15% of calories from saturated fat, or 1 g or less per 100 g and under 10% of calories for meals and main dishes.

The proposed change there is procedural. A food bearing "low saturated fat" would also need to show "Low" for saturated fat in the box, while a "low sodium" food would need to display "Low" for sodium. The claim and box would have to agree.

Proposed compliance timeline, cost and industry response

FDA proposed a compliance date of 3 years after the final rule's effective date for businesses with $10 million or more in annual food sales, and 4 years for smaller firms.

Those clocks begin only if and when a final rule is published. Nothing has started.

Any article giving you a firm U.S. front-of-package compliance deadline is therefore inventing one. The deadlines that actually exist are collected in FDA nutrition label changes.

FDA's primary estimate of annualized costs was $333 million, with a range of $191 million to $530 million, over 10 years at a 2% discount rate in 2023 dollars. That estimate drives much of the industry debate.

Two prominent industry positions pull in different directions. The Consumer Brands Association promoted its voluntary "Facts up Front" system instead, arguing that a mandatory box is unnecessary.

FMI asked FDA to add calories, cover more nutrients, drop or reconsider "Med," and allow placement in the bottom third. The SBA Office of Advocacy argued that FDA understated the burden on small firms.

Those disagreements make a re-proposal plausible rather than making straightforward finalization the only possible path.

For comparison, look north. Canada's front-of-package nutrition symbol is not a proposal. It is mandatory and has a real compliance date, covered in the Canada front-of-package deadline article. If you sell into both markets, one obligation is real today and the other is not.

What manufacturers should do about the proposed rule now

Nothing is mandatory. There is no Nutrition Info box to add, no artwork to change and no deadline to meet.

FDA has not authorized a voluntary format, so creating your own "Nutrition Info" box risks a misbranding problem rather than giving you a head start.

What you can do costs almost nothing because you already have the inputs. For each SKU, record:

1. Saturated fat %DV.
2. Sodium %DV.
3. Added sugars %DV.
4. Apply the proposed bands: 5% or less is Low, 6% to 19% is Med, and 20% or more is High.

That gives you a portfolio map. You can see how many SKUs would display "High," which products sit within a gram or 20 milligrams of moving into a better band, and which "low sodium" claims are exposed to the proposed 115 mg threshold.

That work is still useful if the final rule changes shape because it inventories your products against the same 5/20 thresholds.

Front of package nutrition labeling frequently asked questions

Is the FDA front of package nutrition label required now?

No. FDA proposed the rule on 16 January 2025, and it has not been finalized. No packaged food in the United States is currently required to carry the proposed front-of-package Nutrition Info box. There is also no compliance date because the proposed compliance clocks would begin only after a final rule takes effect.

Why is there no calorie count in the FDA Nutrition Info box?

FDA proposed a three-nutrient box containing saturated fat, sodium and added sugars only. Proposed 101.6(a)(4) would prohibit anything else inside it. Calories could still appear elsewhere on the front panel under existing rules. FMI asked FDA to add calories, but FDA has not said whether that request will be incorporated.

Could the final front of package nutrition labeling look different?

Yes. In March 2026, FDA leadership said they "did not like the front-of-package plan that we inherited" and that "everything is on the table," including changes large enough to require re-proposing the rule for another comment period. Treat the heading, three nutrients, Low/Med/High terminology and upper-third placement as proposed design, not settled design.

Does the proposal change what counts as "low sodium"?

It would if finalized as written. The proposal would lower the threshold from 140 mg to 115 mg or less per RACC so the claim aligns with the 5% DV "Low" band. Until then, the binding definition in 21 CFR 101.61 remains 140 mg per RACC, so a product containing 130 mg per RACC can still be labeled "low sodium" today.

Are small packages exempt from the proposed Nutrition Info box?

Packages with less than 12 square inches available to bear labeling would be exempt outright. Packages of 40 square inches or less could use a reduced box without column subheadings or numeric %DVs, showing only Low, Med or High beside "Sat. Fat," "Sodium" and "Add. Sugar." Gift assortments and certain unit containers in multiunit packages would also be exempt.

While the front-of-package rule remains pending, the Nutrition Facts panel it would sit beside is already binding and enforceable. Build a compliant panel with correct %DVs for saturated fat, sodium and added sugars in the nutrition label generator, then check each product against the proposed Low, Med and High bands using the %DV calculator.