Labels for retail cases, wholesale drops, and online orders
Retail bakeries selling packaged bread, cookies, and pastries need FDA labels the same as any CPG brand. Wholesale-only exemptions have limits.
First question: does your bakery need a Nutrition Facts panel at all?
Most small bakeries are closer to exempt than they expect, and most of the ones that are exempt do not realise the exemption has conditions attached. Three separate provisions of 21 CFR § 101.9(j) matter here, and they do different things.
The retail-establishment provision covers food you both make and sell in the same shop. Croissants in your own display case, boxed and handed across your own counter, generally fall outside the labeling requirement. The moment those same croissants leave for a wholesale account, a farmers market stall, or a shipping box, they are packaged food in interstate commerce and the ordinary rules apply.
The small-business exemption under § 101.9(j)(18) covers businesses selling fewer than 100,000 units into the US in a twelve-month period with fewer than 100 full-time-equivalent employees. This one is not automatic: it requires filing FDA Form 3570, and refiling every year. A bakery that qualifies but never files is not exempt.
There is also a turnover-based exemption under § 101.9(j)(1) for very low gross sales, which does not require a filing.
The thing that quietly voids all of it
Every one of those exemptions disappears the moment you make a nutrient content claim or a health claim. "Low fat." "High fiber." "Sugar free." "Made with whole grain." "Only 90 calories." Put any of that on the package, the shelf tag, or arguably the marketing that travels with the product, and you have opted into full Nutrition Facts labeling for that item - retroactively, for the product as sold.
This is the most common way a bakery that was genuinely exempt ends up non-compliant. The claim goes on a sticker because it helps the product sell, and nobody connects it back to the labeling obligation it just triggered. If you are relying on an exemption, the safest posture is to keep the package free of claim language entirely.
| Per 100g | |
|---|---|
| Energy | 2092 kJ / 500 kcal |
| Fat | 25 g |
| of which saturates | 13 g |
| Carbohydrate | 64 g |
| of which sugars | 36 g |
| Protein | 7.1 g |
| Salt | 0.8 g |
| Fat / Lipides | 7 g | 9 % |
| Saturated / Saturés | 3.5 g + Trans 0 g | 18 % |
| Cholesterol / Cholestérol | 10 mg | 3 % |
| Sodium | 95 mg | 4 % |
| Carbohydrate / Glucides | 18 g | 7 % |
| Fibre / Fibres | 1 g | 4 % |
| Sugars / Sucres | 10 g | 10 % |
| Protein / Protéines | 2 g | |
| Vitamin D / Vitamine D | 0 mcg | 0 % |
| Calcium | 10 mg | 1 % |
| Iron / Fer | 1 mg | 4 % |
| Potassium | 45 mg | 1 % |
*5 % ou moins c'est peu, 15 % ou plus c'est beaucoup
Small packages: tabular and linear formats
Individually wrapped cookies, single brownies, and small pastry packs often do not have the surface area for a standard vertical panel. § 101.9(j)(13) provides for this: below defined thresholds of available label space you may use the tabular or linear display instead of the full vertical block, and the smallest packages can defer nutrition information to an address or phone number on the label.
NFL selects the appropriate format from the surface area you enter rather than making you look up which threshold you fall under. All three FDA formats - standard vertical, tabular, and linear - are free forever.
Ingredient sub-lists, which bakeries have more of than anyone
Bakery ingredient statements nest deeper than almost any other category. Your enriched flour carries six sub-ingredients. Your chocolate chips carry five. Your baking powder carries three. Under § 101.4 each of those has to appear in parentheses after its parent ingredient, in descending order of predominance, and the parent ingredients themselves have to be in descending order by weight.
Doing that by hand for a recipe with fourteen inputs is where most self-built bakery labels go wrong. NFL renders the nesting from your recipe automatically and re-sorts it every time you change a quantity.
Wheat, and the other eight
Wheat is one of the nine major food allergens, which means it is in essentially every product you make. Milk, eggs, and tree nuts cover most of the rest of a bakery's range, and sesame joined the list under the FASTER Act - a change that caught a lot of bakeries out, because sesame appears on far more bread and bun products than people expect.
NFL bolds the allergen inside the ingredient statement and generates the "Contains:" line from the ingredients themselves, so adding sesame seeds to a topping updates the allergen declaration without you remembering to go back and edit it.
Batch cost and margin, from the same recipe
The same recipe that produces the label produces the costing. Track cost per baker's dozen, per loaf, or per cookie, set a target margin, and back-calculate the wholesale and retail price. Ingredient price changes flow through to every product that uses them, which matters when flour or butter moves and you need to know which lines stopped being profitable.