Label Formats for Small Packages
The measurement that decides everything is total surface area available to bear labeling, not the principal display panel. What 12 square inches buys you, what 40 square inches allows, and why tabular comes before linear.
A small package nutrition label is decided by one measurement, and it is not the one most producers reach for. The threshold in 21 CFR 101.9(j)(13) is the package's total surface area available to bear labeling. Two numbers matter: 12 and 40. Below 12 square inches a food can be exempt from nutrition labeling altogether. At 40 square inches or less it can compress the panel in three specific ways. Above 40 the standard format applies, with one narrow relief valve.
Everything here is the exception. The baseline vertical format, the mandatory nutrients and the standard type sizes are covered in Nutrition Facts label requirements; this piece picks up where the package is too small to hold what that article describes.
The measure that decides everything is not the principal display panel
This is the mistake that sends producers down the wrong branch before they have read a word of the format rules. Section 101.9(j)(13) is keyed to "total surface area available to bear labeling". Section 101.1 defines something different, "area of the principal display panel", and the two are not interchangeable.
Under 101.1 the principal display panel is the part of the label most likely to be displayed, presented, shown or examined under customary conditions of display for retail sale, and its area is computed one of three ways: for a rectangular package where one entire side can properly be considered the principal display panel side, the height times the width of that side; for a cylindrical or nearly cylindrical container, 40 percent of the height times the circumference; for any other shape, 40 percent of the total surface, except where the container presents an obvious principal display panel such as the top of a circular package of cheese, where it is the entire top surface. Tops, bottoms, can flanges, and shoulders and necks of bottles or jars are excluded.
Those formulas deliberately measure a fraction of the package, because their job is to set type size for the net quantity of contents declaration, which sits on one panel: 101.7(i) uses the figure directly, stepping from not less than 1/16 inch where the principal display panel is 5 square inches or less up to 1/2 inch above 400 square inches. Total surface area available to bear labeling is the other quantity, how much of the package can carry printing at all. On a four-sided carton that is closer to the sum of the usable panels than to any one of them. Section 101.9 does not restate a formula for it, so if your package sits near a threshold, document how you measured. What you must not do is compute a principal display panel area under 101.1, find it below 12, and claim the exemption on that basis: a cylindrical container whose 40 percent principal display panel area is 10 square inches has a total labeling surface well above 12. Work the panel geometry out with the principal display panel calculator, keep that figure for net quantity, and measure the whole labelable surface separately for 101.9.
Under 12 square inches: the small package nutrition label exemption and its price
Paragraph (j)(13)(i) exempts foods in small packages that have a total surface area available to bear labeling of less than 12 square inches. The condition is strict: the labels must bear no nutrition claims or other nutrition information in any context on the label or in labeling or advertising, except as provided in 101.8(c). The rule states the consequence outright, that claims or other nutrition information subject the food to the provisions of the section. There is no partial version, and "other nutrition information" is written more broadly than the defined claims in 101.13. One claim on the wrapper, or in the advertising, and the whole panel becomes mandatory.
Paragraph (j)(13)(i)(A) requires the manufacturer, packer or distributor to provide on the label of packages that qualify for and use the exemption an address or telephone number that a consumer can use to obtain the required nutrition information. The rule's own example is "For nutrition information, call 1-800-123-4567". Either one satisfies it, but it has to be identified as the route to nutrition information rather than simply being the manufacturer's address already required elsewhere.
Paragraph (j)(13)(i)(B) governs labeling anyway. When such products bear nutrition labeling, either voluntarily or because nutrition claims or other nutrition information is provided, all required information must be in type size no smaller than 6 point, or all upper-case type of 1/16 inch minimum height. One carve-out: individual serving-size packages of food served with meals in restaurants, institutions and on board passenger carriers, and not intended for sale at retail, may instead comply with 101.2(c)(2), which allows type no smaller than 1/32 inch where the package has a total area of 3 square inches or less available to bear labeling and there is insufficient area to print everything at 1/16 inch.
The footnote gets a relief. Foods in packages subject to (j)(13)(ii)(A)(1) and (2), the tabular and linear small package displays, do not require the information in (d)(9) and (f)(5) related to the footnote. The standard (d)(9) text, "The % Daily Value tells you how much a nutrient in a serving of food contributes to a daily diet. 2,000 calories a day is used for general nutrition advice," can be dropped, and the abbreviated statement "% DV = % Daily Value" may be used instead.
Forty square inches or less: the three modifications 101.9(j)(13)(ii) allows
Foods in packages with a total surface area available to bear labeling of 40 or less square inches may modify the requirements of paragraphs (c) through (f) and (i) by one or more of three means. "One or more" matters: they are independent, and you take only the ones you need.
- (A) Format. Presenting the required nutrition information in a tabular or, subject to a further condition, linear fashion rather than in vertical columns.
- (B) Abbreviations. Using any of fifteen listed abbreviations for nutrient and heading names.
- (C) Placement. Presenting the required nutrition information on any label panel.
(C) is worth more than it looks. Section 101.9(i) says that except as provided in (j)(13) and (j)(17), the location of nutrition information must comply with 101.2, which confines required information to the principal display panel or the information panel, the panel immediately contiguous and to the right of it. Section 101.2(d)(1) carries the same carve-out from the other direction, so a 40 square inch package can put the panel on the back, the bottom or a side flap.
Two reliefs attach from outside. Under 101.9(c)(8)(ii) the quantitative amounts by weight for vitamin D, calcium, iron and potassium are not required for labels described in (j)(13), so those rows can carry the percent Daily Value alone. Under 101.9(b)(12)(i)(A) the dual column requirement for individually packaged products holding at least 200 and up to 300 percent of the reference amount does not apply to products meeting the requirements for the tabular format in (j)(13)(ii)(A)(1) or the linear format in (j)(13)(ii)(A)(2).
Above 40 square inches the standard format governs, with one relief valve in (j)(17): where the principal display panel and information panel lack sufficient space, the label may go on any alternate panel readily seen by consumers. The tests are asymmetric. Space needed for vignettes and other nonmandatory information on the principal display panel may be considered; nonmandatory information on the information panel may not. Artwork can move the panel off the front, not off the information panel, and the format and type size are unchanged. The rest of 101.9(j) is collected in our FDA labeling reference.
Tabular first, linear only when the tabular will not fit
Subparagraph (A) is one long sentence with three conditions stacked inside it, and reading them in order settles most arguments. The tabular or linear display may replace vertical columns in either of two situations. First, if the product has a total surface area available to bear labeling of less than 12 square inches; nothing else is required, being that small is enough. Second, if the product has a total surface area available to bear labeling of 40 or less square inches and the package shape or size cannot accommodate a standard vertical column or tabular display on any label panel. Between 12 and 40 square inches the format change is not a choice: you have to be unable to fit a standard vertical column on any panel.
Then the closing sentence cuts again. Nutrition information may be given in a linear fashion only if the label will not accommodate a tabular display. Linear, the string format where nutrient names and amounts run on as continuous text rather than sitting in a column, is available only once the tabular has been ruled out on the same package. The order is vertical, then tabular, then linear, and you move down only when the one above genuinely will not fit.
The linear display gets a structural exemption to match: (d)(7), which requires each nutrient name to sit in a column followed by its weight with percent Daily Value aligned in its own column, opens with "Except as provided for in paragraph (j)(13)(ii)(A)(2)". And (d)(2), which requires the "Nutrition Facts" heading to be set the full width of the nutrient information, excepts labels under (d)(11), (d)(13)(ii), (e)(6)(ii), (j)(13)(ii)(A)(1) and (j)(13)(ii)(A)(2), so on either small package display the heading need not run full width.
The abbreviations, exactly as the rule lists them
Subparagraph (B) gives a closed list. Shortening a nutrient name that is not on it is not covered by (j)(13).
| Full term | Permitted abbreviation | Also allowed outside small packages |
|---|---|---|
| Serving size | Serv size | No |
| Servings per container | Servings | No |
| Calories from saturated fat | Sat fat cal | No |
| Saturated fat | Sat fat | No |
| Monounsaturated fat | Monounsat fat | No |
| Polyunsaturated fat | Polyunsat fat | No |
| Cholesterol | Cholest | No |
| Total carbohydrate | Total carb | Yes, on dual-column displays under (e)(5), (e)(6)(i) and (e)(6)(ii) |
| Dietary fiber | Fiber | No |
| Soluble fiber | Sol fiber | No |
| Insoluble fiber | Insol fiber | No |
| Sugar alcohol | Sugar alc | No |
| Vitamin | Vit | Yes, on the standard vertical side-by-side display in (d)(12) |
| Potassium | Potas | Yes, on the standard vertical side-by-side display in (d)(12) |
| Includes | Incl | Yes, on dual-column displays under (e)(5), (e)(6)(i) and (e)(6)(ii) |
Four of the fifteen travel beyond small packages, and the rule says so in the list itself. "Total carb" and "Incl" may also be used on the dual-column displays in (e)(5), (e)(6)(i) and (e)(6)(ii); "Vit" and "Potas" may also be used on the standard vertical side-by-side display in (d)(12). The other eleven are small package provisions only.
The type sizes that shrink, and the ones that do not
Paragraph (d)(1)(iii) sets the type sizes and then carves out the small package displays by name. The reductions are narrower than most people assume: calories and the serving statements shrink, the nutrient rows do not.
| Element | Standard vertical format | Small package tabular and linear |
|---|---|---|
| "Calories" word, (d)(5) | No smaller than 16 point, bold or extra bold | No smaller than 10 point |
| Calories numeral, (d)(5) | No smaller than 22 point, bold or extra bold | No smaller than 14 point |
| Servings per container, (d)(3)(i) | No smaller than 10 point | No smaller than 9 point |
| Serving size, (d)(3)(ii) | No smaller than 10 point, bold or extra bold | No smaller than 9 point |
| Nutrient names, amounts and %DV, (d)(7) and (d)(8) | No smaller than 8 point | No smaller than 8 point, unchanged |
| "Amount per serving", "% Daily Value*", footnote, (d)(4), (6), (9) | No smaller than 6 point | No smaller than 6 point, unchanged |
The 16 point to 10 point reduction for the "Calories" word also applies to the tabular displays in (d)(11) and (e)(6)(ii), and so does the serving size reduction to 9 point. The 22 point to 14 point calories numeral and the 9 point servings per container are named only for the two small package displays. Separately, if the "Serving size" declaration does not fit in the allocated space, 8 point may be used on packages of any size under (d)(3)(ii), and on the linear display the actual number of servings may be listed after the servings per container declaration under (d)(3)(i).
Do not confuse the two 6 point figures. The floor in (j)(13)(i)(B) applies to a sub-12 square inch package labeling under the exemption route; the figures in (d)(1)(iii) are element-specific minimums on any format. Neither licenses 6 point nutrient rows on a 30 square inch package, where the 8 point minimum governs.
Working the decision in order
Measure the total surface area available to bear labeling and record how you measured it. If it is less than 12 square inches, decide whether you can live without any nutrition claim or nutrition information anywhere on the label, in labeling or in advertising. If you can, take the exemption and put an address or telephone number on the pack that a consumer can use to obtain the nutrition information. If not, you are labeling, and you go to (j)(13)(ii).
At 40 square inches or less, take only the modifications you need. Try a standard vertical column on every panel first; if none will hold one, go tabular; go linear only when the label will not accommodate the tabular display. Then apply the abbreviations from the list, drop the footnote in favour of "% DV = % Daily Value", drop the quantitative weights for vitamin D, calcium, iron and potassium, and place the panel wherever it works. Keep the reasoning on file, because the shape and size test in (j)(13)(ii)(A) is the part a reviewer will ask you to justify. Build the panel itself in the nutrition label generator, which lays out the tabular and linear small package displays at the reduced type sizes above.
Frequently asked questions
Is the 12 square inch threshold measured on one panel or across the whole package?
Across the whole package. The phrase in 101.9(j)(13) is "total surface area available to bear labeling", the labelable surface of the package, not one panel. The principal display panel area in 101.1 is a different quantity computed a different way: height times width of one side for a rectangle, or 40 percent of height times circumference for a cylinder. Using the principal display panel figure to claim the exemption is the most common way producers get this wrong.
Does a "good source of fiber" claim cost me the under 12 square inch exemption?
Yes. The proviso in (j)(13)(i) requires that the labels bear no nutrition claims or other nutrition information in any context on the label or in labeling or advertising, except as provided in 101.8(c), and claims or other nutrition information subject the food to the provisions of the section. The exemption is all or nothing, and it reaches advertising, not just the wrapper.
Can I use the linear format because it fits my artwork better?
No. Paragraph (j)(13)(ii)(A) ends by stating that nutrition information may be given in a linear fashion only if the label will not accommodate a tabular display. Layout preference is not a qualifying reason; you must first establish that the tabular display will not fit.
My package is 30 square inches and a vertical column fits on the back panel. May I still use the tabular display?
No. Between 12 and 40 square inches the format change in (j)(13)(ii)(A) is conditioned on the package shape or size being unable to accommodate a standard vertical column or tabular display on any label panel, so if a vertical column fits on any panel you use it. Below 12 square inches that test does not apply and the tabular or linear display is available on size alone.
Do I still need the Daily Value footnote on a small package panel?
Not on the tabular or linear small package displays. Paragraph (j)(13)(i) states that foods subject to (j)(13)(ii)(A)(1) and (2) do not require the information in (d)(9) and (f)(5) related to the footnote, and that the abbreviated statement "% DV = % Daily Value" may be used.
Does the exemption also cover the ingredient list and net quantity?
No. Section 101.9(j)(13) is an exemption from 101.9 only. The ingredient statement, statement of identity, name and place of business and net quantity of contents are governed by their own sections. Section 101.2(c) still sets a general floor of 1/16 inch in height for information on the principal display panel or information panel, and net quantity type size still follows the principal display panel tiers in 101.7(i), starting at 1/16 inch for a panel of 5 square inches or less.
