課題
商品もラベルデザイナーも棚に並ぶ日程も揃っている。足りないのは、Nutrition FactsブロックでtotalFatを4gに丸めるのか4.5gに丸めるのかを判断してくれる規制の専門家です。SKU1つのために専門家を雇っても採算は合いません。
NFLができること
- USDA FoodData Centralのデータを用いて、原材料リストからすべての栄養素を自動計算
- FDAの 21 CFR 101.9 における丸め規則と非有意基準を自動適用するため、調べ直す必要がありません
- FALCPA + FASTER Act のチェックボックスから「Contains:」アレルゲン行を生成
- 印刷対応のPDF、PNG、SVG、JPG、EPS、AIを書き出し - デザイナーが必要とするファイル形式に対応
対象となる方
少量生産のソース、焼き菓子、ジャーキー、グラノーラ、ナッツバター、冷凍食品、植物性乳代替品 - ファーマーズマーケット、地域の食料品店、DTCのEC販売を行い、大企業並みの予算をかけずに法令に適合したラベルが必要なすべての方へ。
The five things every packaged food label has to carry
Nutrition Facts is one element of a compliant label, not the whole of it. A packaged food sold in the US generally needs all five of these, and missing any one of them is a labeling violation on its own:
1. Statement of identity. What the product actually is, in the product's common or usual name, on the principal display panel - the face the customer sees on shelf. "Aunt May's" is a brand, not an identity. "Aunt May's Blueberry Preserve" is.
2. Net quantity of contents. In both metric and US customary units, positioned in the bottom 30% of the principal display panel under § 101.7. This placement rule surprises people constantly - a correct weight in the wrong third of the panel is still wrong.
3. Ingredient statement. Every ingredient by common name, in descending order of predominance by weight, with sub-ingredients in parentheses per § 101.4.
4. Name and place of business of the manufacturer, packer, or distributor, per § 101.5 - qualified with "Manufactured for" or "Distributed by" if the named firm did not make it.
5. Nutrition Facts and allergen declaration, unless a specific exemption applies to you.
If you are cooking from home, read this part first
Home-based food businesses usually operate under a state cottage food law rather than the federal packaged-food regime, and those are genuinely different rules with a different shape.
Cottage food laws are state-level and vary substantially - in which foods they permit, what sales ceiling they impose, and whether they require a permit or inspection. Most restrict you to shelf-stable, non-potentially-hazardous products: baked goods, jams, dry mixes, candies. Most require a specific disclosure on the label along the lines of "Made in a home kitchen that is not subject to state inspection." And most importantly, most confine you to selling within your own state.
That last constraint is the one that ends the arrangement. The day you ship to a customer in another state, you are in interstate commerce, your cottage food licence stops covering you, and the full federal labeling rules apply. Plenty of home businesses cross that line the first week they turn on online ordering, without realising the legal basis they were operating under just evaporated.
Check your own state's cottage food statute before you rely on it. They differ enough that no general description is a substitute for reading yours.
Where the exemptions actually apply
Even in interstate commerce, small operations may not need a Nutrition Facts panel. Two federal provisions matter: § 101.9(j)(1), a turnover-based exemption for very low gross sales, and § 101.9(j)(18), covering businesses selling fewer than 100,000 units into the US in twelve months with fewer than 100 full-time-equivalent employees.
The second requires filing FDA Form 3570, annually. It is not automatic and a business that qualifies but never files is not exempt.
And both vanish the moment you make a nutrient content or health claim. "Low sugar," "high protein," "keto-friendly," "only 100 calories" - any of these on the package opts you into full nutrition labeling for that product. If you are leaning on an exemption, keep claim language off the pack.